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British Airways learns a lesson on controls

Tom Fox | June 12, 2017

The myth of the lone wolf in FCPA enforcement actions is just that, a myth. Some commentators bemoan how unfair it is that companies must pay for the sins of their corrupt employees. These commentators refuse to acknowledge (1) the company benefited from the nefarious conduct because they accepted the inevitable profits generated by the business obtained through the corruption and (2) the company knew or should have known about the conduct.

If the company knew about the conduct, it clearly was involved in the fraud. If it turned a blind eye by failing to put proper controls in place to manage the risk, it is guilty of conscious indifference. A robust compliance program would identify the risks, and part of the management of such risks would require controls around the risks to prevent, detect, and remediate them going forward. It is this integrated nature of what a compliance program should consist of that effectively precludes the existence of a lone wolf argument.

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