Up until now, there is always one business person at a conference who says something along the lines of “Why should I spend $200,000 to $500,000 to implement a FCPA compliance solution when the chances of getting caught and sanctioned are quite low?” My immediate response is “Remember the Ford Pinto?” Recognizing there will always be the Neanderthal approach to compliance the usual compliance discussion is “what do I have to do to follow the law?” However, that discussion may well become “what do I have to continue to operate my company and transact business” all within the compliance context. I have recently seen this change in three areas: the integration of compliance into overall risk management and business financing.
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