31 Days to a More Effective Compliance Program - Code of Conduct as an internal control

Thomas Fox
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In 2016, one of the most interesting non-international focused FCPA enforcement actions was announced by the SEC. It involved a clear quid pro quo benefit paid out by United Airlines, Inc. to David Samson, the former chairman of the Board of Directors of the Port Authority of New York and New Jersey, the public government entity which has authority over, among other things, United’s operations at the company’s huge east coast hub at Newark, New See more +
In 2016, one of the most interesting non-international focused FCPA enforcement actions was announced by the SEC. It involved a clear quid pro quo benefit paid out by United Airlines, Inc. to David Samson, the former chairman of the Board of Directors of the Port Authority of New York and New Jersey, the public government entity which has authority over, among other things, United’s operations at the company’s huge east coast hub at Newark, New Jersey.

Three key takeaways:

1. It is very unusual for the FCPA to form the basis of a domestic bribery violation.

2. A Code of Conduct can be an internal control.

3. Even a CEO must follow internal controls. 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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