Most compliance practitioners are aware of Hallmark Number 10 in the Ten Hallmarks of an Effective Compliance Program, which discusses mergers and acquisitions in the compliance context. You need to perform an appropriate amount of pre-acquisition due diligence, so that you can adequately evaluate the FCPA compliance status of your target. Post-acquisition, you are required to perform a full forensic audit, while training personnel in the acquired entity and integrating them into your compliance regime.
