Paul McNulty, former United States Deputy Attorney General has provided perspective that there are three general areas of inquiry the Department of Justice (DOJ) would assess regarding an enforcement action. First: “What did you do to stay out of trouble?second: “What did you do when you found out?” and third: “What remedial action did you take?” He also discusses that as a key component, a company must document its overall compliance efforts.
Former federal prosecutor Stephen Martin, currently the General Counsel of Corpedia, discusses the key component of documentation when he and I speak across the country on current compliance best practices in our World-Check sponsored Foreign Corrupt Practices Act (FCPA) events. To respond to any of these inquiries a company must document what it does for its compliance efforts. However, more than simply the ability to document the results of your company’s compliance efforts is the ability of a company to quickly and efficiently respond to a prosecutor’s request for information in a timely manner.
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