Many commentators looked back at the events of 2011 in
the compliance arena and have looked forward into 2012. However, most of the
commentators in the United States focused on the US Foreign Corrupt Practices
Act for both their retrospective and Great Carnac tea leaf readings. This lack
of international focus is rectified in the January, 2012 issue of the Compliance Week Magazine, in an
article entitled, "Ten
Global Compliance Trends to Watch in 2012" by Neil Baker. The issues
presented on the list are matters which any compliance professional from a US
company, which has international operations should review and be prepared to
This list that Baker has put together clearly portends
greater compliance convergence. A Compliance Officer well versed in
anti-corruption legislation across the world will have a myriad of laws to
navigate to keep his company on the right side of anti-corruption laws.
However, the Compliance Officer may well have a broader remit in 2012. Baker
ends his piece with this cheery note, "There's never a good time for a company
to suffer a compliance failure, but 2012 would be a particularly bad time."
Visit the FCPA Compliance and Ethics Blog,
hosted by Thomas Fox, for more commentary on FCPA compliance, indemnities and
other forms of risk management for a worldwide energy practice, tax issues
faced by multi-national US companies, insurance coverage issues and protection
of trade secrets.
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© Thomas R. Fox, 2012
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