The CCO and Crisis Management

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“What, Me Worry?” is one of my favorite all-time slogans. Anyone who grew up on the 60s or 70s recognizes this comes from Alfred E. Neuman, the enigmatic face of Mad Magazine. While this phrase certainly had its uses for us teenagers back then, it is not a by-word for how the compliance practitioner needs to prepare for a compliance crisis, usually in the form of the discovery of a potential Foreign Corrupt Practices Act (FCPA) violation. Fortunately, Ileana Blanco has provided somewhat better guidance that than of my former guiding spirit. In the February 27, 2012 edition of the Texas Lawyer, in an article entitled “In-House Counsel’s Guide to Crisis Management”, Ms. Blanco detailed what she believes are the best practices for an in-house counsel in responding to a legal catastrophe.

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