WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)
The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate acquisition targets into existing compliance programs. At bottom, WPP and its subsidiaries lacked any culture of compliance. While it is easy to cite all the deficiencies in the WPP subsidiaries, such a focus misses...