Best Practices for Anti-Corruption Compliance Programs – A Moving Target
The Justice Department and the SEC have pushed extraordinary changes in the field of anti-corruption compliance. If one looks back five years ago and compares the so-called best-practices from 2008 and compares them to recent pronouncements on anti-corruption compliance, the differences are stark. Here is a summary chart on current program elements and some “best practices” cited by DOJ and the SEC in recent enforcement...