In this post we are concluding our review of the Tyson Foods settlement, which both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced last week, of its violations of the Foreign Corrupt Practices Act (FCPA). In yesterday’s posting we discussed the reasons for the settlement and the specifics of the monetary penalty assessed against Tyson Foods. In today’s posting we will discuss the requirements set forth in the Corporate Compliance Program, which is found as Attachment C to the Tyson Foods Deferred Prosecution Agreement (DPA) and our thoughts on why the Tyson Foods matter falls directly into conduct which the FCPA is designed to prevent.
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