10 Steps To Effective Anti-Corruption Compliance

Law360, New York (May 13, 2013, 11:49 AM EDT) -- The Foreign Corrupt Practics Act resource guide issued by the U.S. Department of Justice and the U.S. Securities and Exchange Commission late last year is an unprecedented public statement of prosecutorial principles. In a six-page discussion, The FCPA resource guide (p. 56-62) contains critical instructions for corporate boards, senior executives and compliance professionals for designing and implementing an “effective” anti-corruption compliance program.

The United States sentencing guidelines (§8B2.1.) define the requirements for an “effective” compliance and ethics program. Even more importantly, The FCPA resource guide (p....
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