How to Create a Post-Acquisition FCPA Compliance Program Integration Plan

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Your company has just made its largest acquisition ever and your Chief Executive Officer (CEO) says that he wants you to have a compliance post-acquisition integration plan on his desk in one week. Where do you begin? Of course you think about the recently released Department of Justice (DOJ) Guidance on the Foreign Corrupt Practices Act (FCPA) but remember that it did not have the time lines established in the recent enforcement actions involving Johnson & Johnson (J&J), Pfizer and Defendant Data Systems & Solutions LLC (DS&S) regarding post-acquisition integration of a FCPA compliance program by an acquiring company into a company. While there are time frames listed in the Deferred Prosecution Agreements (DPAs) that can be ascertained, one of the things that most compliance professionals struggle with is how to perform these post-acquisition compliance integrations. I recently saw an article in the December issue of the Harvard Business Review, entitled “Two Routes to Resilience”, which presented some concepts that I thought might be of use to the compliance practitioner in a post-acquisition compliance program integration scenario. It certainly might give you some ideas to present to your CEO next week.

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