Found on page 54 of the recently released Department of Justice (DOJ) Guidance on the Foreign Corrupt Practices Act (FCPA) is the following language:
“Chapter 8 of the Sentencing Guidelines, which governs the sentencing of organizations, takes into account an organization’s remediation as part of an effective compliance and ethics program.”
Chris Bauer, among others, gently chides me from time-to-time that I do not put enough emphasis on ethics in a FCPA compliance program. Probably part of the reason is that, with my legal training, I tend to think of rules, regulations and laws as the guideposts for corporate conduct. Chris, once again among others, reminds us that corporations are made up of people and that there can never be enough rules and regulations to cover every situation. So if employees have the right ethical compass they would tend to do the right things in business going forward.
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