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Compliance front and center

Tom Fox | June 21, 2016

The past couple of months has confirmed a trend we have seen for some time in the world of Foreign Corrupt Practices Act and greater anti-corruption compliance. It is the continued growth in the importance of doing compliance in the eyes of the Justice Department and Securities and Exchange Commission. They have clearly moved beyond simply having a compliance program in place. It must be operationalized, and you must demonstrate its effectiveness if you want to receive credit for it in any FCPA enforcement action.

In April with the release of the written document, entitled “The Fraud Section’s Foreign Corrupt Practices Act Enforcement Plan and Guidance” and detailing the Pilot Program for FCPA enforcement credit, the Justice Department made clear that it is the doing of compliance that can bring a company “reducing credit.” It also made clear that the role of the chief compliance... To get the full story, subscribe now.