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...