Every compliance practitioner can learn from the Panasonic Avionics FCPA enforcement action earlier this week. There are lessons about the limits of due diligence, the lack of internal controls, management override of existing internal controls, how C-Suite involvement in illegal conduct corrupts an entire organization, and a foreign parent looking the other way when a profitable subsidiary makes a ton of money. However, from this perspective, the most significant learning can be found in the 20 percent discount afforded Panasonic Avionics off its criminal fine.
