31 Days Days to More Effective Compliance Program - Policies and procedures

Thomas Fox
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The specific written policies and procedures required for a best practices compliance program are well known and long established. The 2012 FCPA Guidance stated, “Among the risks that a company may need to address include the nature and extent of transactions with foreign governments, including payments to foreign officials; use of third parties; gifts, travel, and entertainment expenses; charitable and political donations; and facilitating and expediting payments.” Policies help form the basis of expectation and conduct in your See more +
The specific written policies and procedures required for a best practices compliance program are well known and long established. The 2012 FCPA Guidance stated, “Among the risks that a company may need to address include the nature and extent of transactions with foreign governments, including payments to foreign officials; use of third parties; gifts, travel, and entertainment expenses; charitable and political donations; and facilitating and expediting payments.” Policies help form the basis of expectation and conduct in your company. Procedures are the documents that implement these standards of conduct.

Three key takeaways:

1. The Code of Conduct, together with written compliance policies and procedures form the backbone of your compliance program.

2. The DOJ and SEC expect a well-thought out and articulated set of compliance policies and procedures.

3. The Fair Process Doctrine holds for the application of policies and procedures. See less -

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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.

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