The Danger to a Compliance Program of Ineffective In-House Lawyers
The United Technologies FCPA settlement underscored, once again, the harm to a company when lawyers fail to do their job. As outlined in the SEC settlement, an in-house attorney at Otis Elevator was required to review and approve a contract with a third-party, where a cursory due diligence review would have uncovered major red flags. The in-house attorney reviewed the contract without inquiring about the...