Last week I began an exploration of the Pfizer Deferred Prosecution Agreement (DPA) which was announced last week by the Department of Justice (DOJ) in connection with its settlement of Foreign Corrupt Practices Act (FCPA) violations. In Part I, I reviewed the Corporate Compliance Obligations, Attachment C.1. Today we review the Enhanced Compliance Obligations, Attachment C.2 and Corporate Reporting Obligation, Attachment C.3, which Pfizer agreed to implement and operate under. In Part III, I will discuss some of the implications raised by the Pfizer DPA for the compliance practitioner.
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