Law360, New York ( November 6, 2015, 12:37 PM EST) -- When I first began to represent companies on Foreign Corrupt Practices Act matters before the U.S. Department of Justice's Fraud Section, it was not uncommon to appear with a client that had no anti-corruption policy whatsoever. That rarely happens today, and when it does let's just say that explaining how the client is implementing its first policy is not a great icebreaker....
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