There is a wealth of information in the Pfizer DPA and other documents relating to its resolution of these FCPA issues. I would commend all the documents to you to read and see what areas your company may need to look at more closely and how these Compliance and Enhanced Compliance Obligation Attachments may provide insight into areas where you might be lacking or need to enhance your compliance program and coverage. These enhanced obligations could well become the new minimum best practices in the FCPA compliance arena.
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