RAE Non-Prosecution Agreement (Part III)-The Tangible Benefits of Full Cooperation in a FCPA Investigation

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In our prior two postings we reviewed the Non-Prosecution Agreement (NPA or Agreement) entered into by RAE Systems, Inc., and the US Department of Justice (DOJ). In Part I, we reviewed the facts which led to the violations of the Foreign Corrupt Practices Act (FCPA); in Part II, we discussed the Corporate Compliance Program which RAE agreed to implement; and in this final article, we will discuss the Corporate Compliance Reporting that RAE agreed to in its NPA. We will then conclude with some of the lessons which we believe can be learned from this NPA and the implication of these lessons for the FCPA practitioner.

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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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