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Halliburton, the FCPA, and effectiveness

Tom Fox | August 8, 2017

The Justice Department’s Evaluation of Corporate Compliance Programs document, which was released in February, drove home the concept of operationalized compliance. It asked a series of questions designed to determine how well a company had moved compliance into the very fabric of its organization. This document followed a series of Justice Department pronouncements that emphasized whether a compliance program was effective—not only must an organization be doing compliance, but it must also be testing how well it is working, integrating that information back into the compliance program itself, and documenting it.

These key concepts, which the Justice Department has espoused in recent years, all came to bear on a Foreign Corrupt Practices Act enforcement action involving Houston-based Halliburton Inc., which was settled in late July. Although this matter was a civil enforcement action brought by the Securities and Exchange Commission, the same principles...

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