Proactive Use of Systemic Compliance Successes in an FCPA Enforcement Action


We recently looked at an article which reviewed the Department of Justice’s (DOJ) Foreign Corruption Practices Act (FCPA) enforcements with an eye towards the failures of internal controls. This analysis provided a valuable summary of several “lessons learned” regarding the compliance failures of those companies caught up in FCPA enforcement actions. One of the frustrations I hear from compliance professions is that they have a good idea of what not to do but are less sure of more proactive steps which their company’s might glean from published enforcement actions.

Fortunately this void has been filled by our colleague William Athanas with his article, “Demonstrating “Systemic Success” in FCPA Compliance: Identifying and Maintaining Evidence to Respond to Government Investigations . . . Before They Begin” recently published in the ABA Global Anti-Corruption Task Form site. He believes that by analyzing what went right, that companies can equip themselves with powerful evidence to respond to government inquiries and create readily identifiable benchmarks to measure the ongoing effectiveness of their FCPA compliance programs.

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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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