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Expert Analysis

Getting Compliance Right When There Are No Regulations

By Jo Ritcey-Donohue (April 16, 2019, 4:37 PM EDT) -- Over the years, many very smart and successful corporate executives have posed a similar question: "Where does it say that our company has to implement certain, specific compliance controls"? Such questions used to be challenging to answer convincingly in areas such as anti-corruption, economic sanctions and export controls — even though they carried high civil and criminal penalties — owing to the lack of regulations specifying compliance program requirements....

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