All compliance programs are designed to prevent, detect and deter ethical violations. In the United States, they are also designed to bring companies into compliance with the Foreign Corrupt Practices Act (FCPA). However, as important as these programs are, it is equally important for a company to deal with any alleged FCPA violations which may arise. The disclosure to and negotiating with the appropriate US governmental agencies charged with enforcement of the FCPA is as critical task which a General Counsel or Chief Compliance Officer may face. Over the next two posting, we will discuss this topic and give some guidelines which a company may consider if such an eventuality occurs. This post will discuss the issue of whether or not a company should self-report a potential or actual FCPA violation. In our next post, we will continue this discussion by focusing the process after self-disclosure.
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