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Anti-corruption Trends: What to Expect in 2011

Melissa Klein Aguilar | February 22, 2011

A reminder for compliance professionals who think they've got Foreign Corrupt Practices Act compliance in the bag: Don't forget to do a regular gut check.

It's often said, but it bears repeating: That program you have in place only works if it's properly implemented and monitored. “Companies often put a program in place and think they've done their job, but day-to-day nobody's checking that it's working and being used,” says Stuart Altman, a partner in the law firm Hogan Lovells.

Given the current anti-corruption enforcement climate, being able to demonstrate that your program is actually being used is even more important than ever, says Altman. That means having someone—whether it's compliance, internal audit, or an outside consultant or vendor conduct periodic checks to make sure the program is operating as intended. It also means keeping a record of any due diligence to be able to show that the company took...

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