Four Steps to Resolving Your FCPA Compliance Issues

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As regular readers of this blog know I often cite the three maxims of Paul McNutly as the basis for a good compliance program. They are the questions that the government will ask when they come knocking: (1) What did you do to prevent it?; (2) What did you find when you looked into it?; and (3) What did you do when you found out about it?. One of the keys of these ideas is that if you look for something, through investigation or audit, you cannot be afraid to find something, recognize that it is a problem, then move forward to remedy the problem and use it as a lesson learned going forward. I recently saw an advertisement in the Harvard Business Review for the Columbia Business School which was entitled, “How to realize leadership potential” it occurred to me that it was a way to think through and act upon McNulty’s point 3. So with some modification I present a practical method to implement McNulty.

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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, Advanced Compliance Solutions | Attorney Advertising

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