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FCPA Lessons Learned-Failures in Internal Controls

We often write and speak on some of the lesson learned from enforcement actions brought by the Department of Justice (DOJ) under the Foreign Corrupt Practices Act (FCPA). We believe that companies can not only learn from the mistakes of others in implementing or enhancing their compliance program...

McNulty’s Maxims, the Deepwater Horizon and FCPA Internal Controls

I often write about what I call Paul McNulty's three maxims of a Foreign Corrupt Practices Act (FCPA) compliance program: 1) What did you do to prevent it?; 2) What did you do to detect it?; and 3) What did you do to remedy it? I had generally thought that the internal controls component of a...