I am often asked whether the Foreign Corrupt Practices Act can be considered an effective piece of legislation if companies continue to be caught with their collective hands in the FCPA cookie jar or self-admit they have violated the law.
I often respond with the words of Dick Cassin, the founder of the FCPA Blog, who after almost 30 years of work in anti-corruption compliance says that he cannot determine whether there are fewer violations of the law, but there certainly is more compliance. I think Cassin’s response points to the strategic success of the FCPA. Moreover, companies that have more robust compliance program, even if only in response to the FCPA, are better run companies.
