One of the things that my colleague Stephen Martin talks about is the need for strategic planning for your Foreign Corrupt Practices Act (FCPA) compliance program. He suggests a 1, 3 and 5 year strategic plan which you should utilize as a road map for your compliance program in these time frames. Equally important, as a former state and federal prosecutor, he believes that such a document would be an important item to produce to a prosecutor, who might be reviewing your compliance program in the event of a voluntary self-disclosure, a Dodd-Frank or other whistleblower event, which has led your company to receive a subpoena or letter of inquiry or an industry sweep. He believes that such a strategic plan could well lead to the development of credibility for your company and your compliance program in the event of one of the aforementioned eventualities.
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