Stepping Up Your FCPA Compliance Program

, Corporate Counsel


When the Feds come knocking about Foreign Corrupt Practices Act violations, companies should be able to prove that they've taken the right compliance measures.

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What's being said

  • Ethan S. Burger

    . . . . an effective FCPA program needs to be carefully tailored to the entity that has adopted and implemented the program.

    This requires a commitment by managers at all levels and can only truly judged over time.

    Often the effectiveness of management systems degrade once the event that triggered their development becomes something far in the past.

    I would suggest that appropriate individuals read relevant websites (DoJ, SEC, and the "fcpaprof") so that they are current on this issue.

    Handbooks, hotlines, training and termination of culpable persons is often not enough.

    Let‘s hope the example you cited proves to be a good model.

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