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Happy Birthday to the FCPA Guidance

Tom Fox | November 22, 2017

The joint Department of Justice and Securities and Exchange Commission  2012 FCPA Guidance came out five years ago this month. All compliance practitioners should thank the government regulators and prosecutors who had a part in drafting this most remarkable of documents. The Man From FCPA believes it is the best government generated source regarding what constituted at the time (and probably still does) a best practices compliance program. For anyone interested in exploring the lessons learned about Foreign Corrupt Practices Act compliance programs and what the government expects to see, the 2012 FCPA Guidance is the best document you can start with.

The “Ten Hallmarks of an Effective Compliance Program”, is still a useful part of the FCPA Guidance. While the Guidance cautions that there is no “one-size-fits-all” compliance program, it recognizes a variety of factors such as size, type of business, industry and risk profile a company should determine for its own... To get the full story, subscribe now.