So how does this relate Foreign Corrupt Practices Act (FCPA) compliance? It is the lesson that that all is not as it may appear at first blush. In an article in the November issue of the ACC Docket, entitled “Wearing Two Hats-In-House Counsel and Compliance Officer”, author Amy Hutchins joins the continuing debate of whether a General Counsel (GC) should also be a company’s Chief Compliance Office (CCO). She reviews certain cases involving the health care industry and touches upon the Federal Sentencing Guidelines which require that “High-level personnel shall ensure that the organization has an effective compliance and ethics program.”
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