Documentation and the TRACE Due Diligence Guidebook

One of the themes coming out of the talks given by representatives of the Department of Justice and Securities and Exchange Commission at FCPA compliance conferences is that of documentation. While many companies focus on the specifics of a best practices FCPA compliance program, we believe that...

Internal Controls under the UK Bribery Act and FCPA

Although much is still unclear about the implementation date, or the manner in which the UK Bribery Act will be enforced, it is clear that one of the important compliance functions which a company should implement is appropriate internal controls. The previously released Consultative Guidance had...