One new and different item laid out in the Evaluation of Corporate Compliance Program (Evaluation), supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance, was ...
In “Managing risky business,” I mentioned that when advice on secure development turns out to be flawed or incomplete, smart organizations learn from their mistakes and update the guidance they issue.
We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) ...
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