What are the Essentials for a FCPA/Bribery Act/OECD Compliance Program

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In a recent article entitled, “Bribery and Corruption Compliance: the Playing Field Levels”, Timothy Coleman and Paul Lomas, attorneys from the law firm of Freshfields Bruckhaus Deringer discuss what they term the “tectonic shift” in anti-bribery and anti-corruption compliance internationally. The authors posit that increased enforcement of the US Foreign Corrupt Practices Act (FCPA); the release of the Organization of Economic Cooperation and Development (OECD) Good Practice Guidance on Internal Controls, Ethics and Compliance (OECD Good Practices); and the impending July 1 implementation date of the UK Bribery Act, have all acted to place “new burdens” on companies to have the highest standard of anti-bribery corruption programs in place.

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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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