FCPA Risk Assessment: Hockey Stick Rather than Bell Curve??

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In an interesting article posted in Industrial Week.com, entitled “Rethinking FCPA Compliance Strategies in a New Era of Enforcement” attorney William Athanas took a different look at assessing the risks for manufacturing companies under the Foreign Corrupt Practices Act (FCPA). His thesis is that such companies assume that FCPA violations follow a “bell-curve distribution, where the majority of employees are responsible for the majority of violations.” However Athanas believes that the distribution pattern more closely follows a “hockey-stick distribution, where a select few…commit virtually all violations.”

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox, Compliance Evangelist | Attorney Advertising

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