Policies on Travel
May 15, 2020
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Prior to the 2012 FCPA Guidance, the DOJ issued two 2007 Opinion Releases which offered guidance to companies considering whether, and if so how, to
Prior to the 2012 FCPA Guidance, the DOJ issued two 2007 Opinion Releases which offered guidance to companies considering whether, and if so how, to
There are numerous reasons to put some serious work into your policies and procedures. They are certainly a first line of defense when the government
Next is the design of your Code of Conduct. Through attention to detail in the design process, you should be able to come out at
What is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early
Over the course of this month, I have presented a variety of specific tools and techniques for the compliance practitioner to utilize to continuous improve
Compliance does not exist in a time-warp vacuum, with compliance programs living in 1977 when the first major anti-corruption legislation, the FCPA, was passed. The
The 2012 FCPA Guidance specified, “a good compliance program should constantly evolve. A company’s business changes over time, as do the environments in which it operates,
Continuous improvement can come in many different, shapes, sizes and packages. As with all things compliance, you are only limited by your imagination. Have you
There are multiple areas in the DOJ’s 2019 Guidance which intersect with the area of continuous improvement. They include the following: Prior Indications – Were there
Determining effectiveness is a key part of continuous improvement. Yet how to do so still bedevils many compliance professionals. You need to consider both outcomes
