The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom line benefits by helping a company avoid or reduce fines and penalties. Much of the recent enforcement action has been focused on liability for bribery and corruption actions performed by third parties on behalf of another company. When it comes to third party corruption, many compliance program leaders worry that they don’t know where to start on a third party compliance program and that they cannot afford the elaborate, richly funded programs that are so often profiled in the news.
Luckily, you don’t have to have a legion of compliance personnel and an unlimited budget to meet standards recently outlined in A Resource Guide to the U.S Foreign Corrupt Practices Act (FCPA Guidance) provided by the United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC).
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