The FCPA Compliance Program Review: Keeping Current and Dynamic

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My colleague, Stephen Martin, speaks about the need to have 1-3-5 plans developed and readily available to upgrade and update your compliance program. He believes that such plans can be useful for several reasons. Initially these plans will be your road map for implementation going forward. Additionally, he believes that such a plan may well be persuasive evidence to a prosecutor or regulator who may be reviewing your Foreign Corrupt Practices Act (FCPA) compliance program. Indeed, this concept is often remarked upon by Lanny Breuer, Assistant Attorney General, for the Criminal Division of the US Department of Justice (DOJ). Last year at Compliance Week 2010, Breuer ended his speech by noting that a compliance program should be “dynamic, not static.” The question becomes how to create such a plan?

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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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