Documentation Can Provide Credibility in a FCPA Investigation


All companies which come before the DOJ when an incident or investigation arises claim that they have the best compliance program that they can afford in place. However, if a company cannot demonstrate the ‘robustness’ of its program it might as well be for naught. I have written several posts on three of the most important components of a FCPA best practices compliance program; which are: documentation, documentation and documentation. I believe that it is true that the only manner in which to gage the overall effectiveness of your compliance program is through documentation. Put another way, if you don’t document it, you cannot measure it and if you cannot measure it, you cannot refine it. Nevertheless, there is one more important aspect to documentation. It is through the access of this documentation that a company put forward support that its compliance program is robust.

LOADING PDF: If there are any problems, click here to download the file.

Written by:

Published In:

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.