Tagged: Lessons learned from societe generale FCPA

Textbook Lessons Learned from the Société Générale and Legg Mason FCPA Enforcement Action (Part III of III)

Textbook Lessons Learned from the Société Générale and Legg Mason FCPA Enforcement Action (Part III of III)

Sometimes it takes a large enforcement action to underscore basic and important anti-corruption compliance principles.  The Société Générale enforcement action demonstrated two important principles – the dangers of a weak corporate culture and the need to apply basic third-party risk management practices to respond to and resolve red flags when they occur. Absence of Culture of Ethics: Société Générale’s culture, as described in the Statement...