The call, email, or tip comes into your office; an employee reports suspicious activity across the globe. That activity might well turn into an FCPA
The 2020 Update was clear about the need for continuous improvement in any compliance program. It succinctly stated, “One hallmark of an effective compliance program
There is nothing like an internal whistleblower report about a compliance violation, the finding of such an issue, or (even worse) a subpoena from the
After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it promptly, thoroughly, and with
After completing your risk assessment, you must translate it into a risk profile. If your estimate of where your bribery risk is greatest is wrong,
One cannot say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based upon a
If there is one truism from the practice of law which translates to the practice of compliance, you are only limited by your imagination. This
One of the areas that many companies have not paid as much attention to in their compliance programs is compensation and incentives. However, the DOJ
One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA and your specific company compliance
A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and
