Ongoing Compliance Assessments: FCPA, UK Bribery Act and OCED Best Practices

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One of the requirements consistent throughout the Principles of Federal Prosecution of Business Organization (US Sentencing Guidelines) and its section on corporate compliance programs; the Organization for Economic Co-operation and Development (OECD) Good Practice Guidance on Internal Controls, Ethics, and Compliance, and the UK Bribery Act’s Consultative Guidance is the need for continued assessment of an anti-corruption and anti-bribery compliance program. This posting will review the specifics of each of these documents and will provide to the compliance and ethics practitioner some ideas on how to implement what each of these protocols stress is key component of any best practices compliance program.

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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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