The Justice Department’s FCPA Corporate Enforcement Policy was announced in November 2017 with much fanfare – it was the culmination of a step-by-step process beginning with the FCPA Pilot Program. The FCPA Corporate Enforcement Policy enshrined the potential benefit of a presumption of a declination if a corporation: (1) voluntarily disclosed the misconduct; (2) implemented timely and appropriate remediation; and (3) fully cooperated with the...
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- Governance, Fraud, and Corporate Culture: Sorting Through a Complicated Relationship April 15, 2021
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- Internal Controls – A Process to Help Ensure Internal Controls are Designed Consistently and Appropriately April 8, 2021