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...
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...