FCPA Compliance: 5 Overlooked Issues
1. Single Compliance Program: A “one size fits all” compliance program does not often work. Must take into account risk/cultural aspects of every country and have a proportionate global program. Must be able to demonstrate compliance program works effectively and has been tested: Prevent-Detect-Respond. Materiality does not matter, issue is whether your internal control system works effectively to detect and avoid illegal payments. 2. Unsupervised 3Ps: Largest source of FCPA violations comes from third parties (3Ps): Agents, Distributors,…