The Freeh Report was released last week. It detailed a series of actions and inactions taken by officials at Penn State University (Penn State) which allowed Jerry Sandusky to continue his abuse of young boys from at least 1998 up until the time he was arrested. This incident is the worst scandal involving the American higher education system that I have witnessed in my lifetime. As noted in a New York Times (NYT) articled published on July 13, entitled “In Report, Failures at Every Level of Hierarchy”, the Freeh Report found a series of failures all the way up the Penn State chain of command. The article stated, “shortcomings that were the result of any insular and complacent culture in which football was revered, rules were not applied and the balance of power was dangerously out of whack.” As bad a situation as the Freeh Report portrays, I believe that there are significant lessons for the Foreign Corrupt Practices Act (FCPA) compliance practitioner and this post will try draw out some of these lessons learned.
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