I recently wrote about my colleague Stephen Martin’s thoughts on having a 1-3-5 year strategic plan for your company’s Foreign Corrupt Practices Act (FCPA) or Bribery Act compliance program. I am often asked where a compliance practitioner can come up with some ideas to put in such a strategic plan. Clearly one excellent area to study are the ongoing enforcement actions, which are all publicly released. They not only provide insight into the Department of Justice’s (DOJ) thinking on current best practices in the area of FCPA compliance programs but with the recent addition of “Enhanced Compliance Obligations” as found in the Johnson & Johnson (J&J) and Pfizer Deferred Prosecution Agreements (DPAs) there is solid information on some of the most cutting edge compliance initiatives which companies are now using. While you should recognize that these “Enhanced Compliance Obligations” are tailored for the specific company the DPA deals with, nevertheless you can review the concepts and implement those which are appropriate for your company.
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