I. Building an effective infrastructure for compliance programs A. The compliance mission: 1. Try to prevent bribery and corruption; but, if detected, the company must respond appropriately B. Key components…
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I. FCPA Overview A. Importance of anti-corruption compliance 1. The Risks a. Substantial criminal fines and penalties b. Imprisonment for individuals c. Investigation costs (e.g., professional fees, legal fees, accounting…
I. Getting to know U.S. Customs and Border Protection (CBP) A. What is CBP? 1. CBP is the Department of Homeland Security’s largest and most complex component. With more than…
I. FCPA Overview A. Importance of anti-corruption compliance B. Elements of the FCPA (15 U.S.C. §78dd-1, et seq.) 1. Anti-Bribery Provision a. Corruptly; b. Offering, promising, authorizing, or…
“Red flag” is a term of art in the FCPA/anti-corruption compliance world. The presence of a red flag does not necessarily mean that illegal conduct has occurred or that the…