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How to Begin Your FCPA Due Diligence

The task of where to begin a full compliance and ethics program can often times appear quite daunting. Most US companies fully understand the need to comply with the Foreign Corrupt Practices Act (FCPA). However most companies are not created out of new cloth but are ongoing enterprises with a fully...

The IBM Case: FCPA Compliance Programs And Internal Controls

There was Congressional testimony last fall to consider possible modifications to the Foreign Corrupt Practices Act. In part the testimony focused on the issue of FCPA compliance procedures as a defense for a business organization. Under current practice those procedures are not a defense but mitigation...

End of the Annual Compliance and Ethics Training ‘Flea Dip’

In an article in the July/August edition of the ACC Docket entitled " Rethinking the Annual Compliance and Ethics Flea Dip ", author James Nortz discusses the annual compliance and ethics training program that most US company's employees receive which he calls a ' flea dip' . While...