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“For tracking litigation, enforcement, and regulatory developments, Compliance Week
should be your prime source.”- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
As BHP Enforcement Shows, the Proof Is in the Doing
Yes, Virginia, you can violate the FCPA even without bribing a foreign government official—just ask BHP Billiton, fined $25 million by the SEC for having a compliance program that looked great on paper, but was never strongly implemented. This week, columnist Tom Fox does a post-mortem on how BHP’s program ...
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