FCPA Due Diligence: How Much Is Enough?

Law360, New York (February 22, 2010, 3:07 PM EST) -- Recent Foreign Corrupt Practices Act actions involving foreign representatives or partners[1] have caused many companies subject to the act to revisit the adequacy of their FCPA due diligence process.

For those who have actual FCPA compliance programs in place, one of the most difficult aspects of the process is successfully identifying circumstances in which additional due diligence is warranted and determining how much more is required. (For those companies that do not have compliance programs in place, we suggest they begin to develop one.)

Government guidelines[2]...
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