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.
