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The Benczkowski Memo – Using External Resources


Vin DiCianni and I have previously considered how companies can use DOJ announcements over the few past year and back to the FCPA Corporate Enforcement Policy, announced in November 2017, to consider what strategies companies can use based upon these documents to internally to bolster their compliance programs and today we consider this same issue from the external perspective. There are several areas from the DOJ guidance which make the use of external resources more impactful for a corporate compliance program.
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