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Internal Controls Under the FCPA

Most Foreign Corrupt Practices Act (FCPA) practitioners understand the requirement for a compliance policy under the FCPA. However many practitioners, particularly lawyers practicing in the compliance field, do not understand the requirement for proper Internal Controls. Generally speaking, Internal...

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...