What Can Your CEO Do for Your FCPA Compliance Program?

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So what can your Chief Executive Officer (CEO) do for your Foreign Corrupt Practices Act (FCPA) compliance program? It turns out quite a bit. Both the US Sentencing Guidelines, which are used as the basis for FCPA compliance programs, and the Consultative Guidance, which is the basis for the adequate procedures defense under the UK Bribery Act, make it clear that top company leadership on compliance and ethics is a key component of any successful anti-bribery and anti-corruption program. Many CEO’s desire to be leaders in this area for their businesses but do not know some of the specific steps that they can take to achieve this. In a book entitled, “Building a World Class Compliance Program – Best Practices and Strategies for Success” author Martin Biegelman provides some concrete examples in the chapter entitled “Tone at the Top and Throughout”.

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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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