When Realities Test The Limits Of Your FCPA Program

Law360 (November 1, 2018, 2:36 PM EDT) -- Compliance counsel and practitioners who advise clients on the Foreign Corrupt Practices Act are undoubtedly familiar with the joint guidance issued by the U.S. Department of Justice and the U.S. Securities and Exchange Commission (the FCPA resource guide),[1] the universe of available FCPA deferred prosecution agreements, and the various other authorities that inform what the government expects from a robust, risk-based anti-bribery compliance program. However, policies and procedures that seem clear and easy to implement when putting pen to paper can become difficult when socializing within a company and even harder during the implementation phase. When practical realities test the limits...

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