The Debate Over A Corporate Compliance Defense

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3 Responses

  1. Howard says:


    Interesting viewpoint. I agree it’s an area where reasonable people can disagree.

    My only question: from when would the 3-year immunity period start? Would we just suspend all FCPA enforcement for three years? Would we not be at risk for decreased compliance spend? Maybe I’m just too cynical: I think companies would spend zero for as long as they could, then say their current program is sufficient. All the money would be spent on audits to find existing issues rather than trying to control for new ones.

    Wow: that did come out cynical. But still too true.

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