Tagged: DOJ FCPA Guidance

Revised FCPA Guidance: Effective Compliance Program and Internal Controls (Part V of V)

The initial FCPA Guidance included valuable compliance program guidance keyed to the heading, “Hallmarks of an Effective Compliance Program.”  Issued in 2012, the outline of an effective compliance program was an important statement of policy. The Revised FCPA Guidance includes additional information, some of which reflect recent changes made to the Evaluation of Corporate Compliance Programs.  The Revised FCPA Guidance includes important statements on internal...