With the ever increasing enforcement efforts under the Foreign Corrupt Practices Act (FCPA), business professionals, in-house lawyers and compliance professionals need concrete guidance on the steps necessary to create or enhance and then implement a best practicescompliance program. In a recently published volume, Lessons Learned on Compliance and Ethics: The Best from the FCPA Compliance and Ethics Blog, Thomas Fox has collected some of his posts that will help guide you in your own journey through the world of anti-corruption and anti-bribery compliance.
He breaks the book down into the following chapters:
Some Thoughts on Best Practices
This section charts some of the evolving standards of a best practices compliance program, with articles on the thoughts of Department of Justice (DOJ) representatives; guidelines from the U.S. Sentencing Commission; standards from the OECD; and comments on the U.K. Bribery Act.
The Nuts and Bolts of Compliance
This area includes articles regarding the “How To” of compliance inside a corporation. As any in-house practitioner knows, the practice of law inside of a corporation is very different from private practice. Fox tries to bring an in-house perspective and provide guidance on how to perform the day-to-day work of implementing, assessing and enhancing a compliance program within a corporation.
Investigations, Enforcement Actions and Legal Issues
In this chapter he discusses ongoing investigations, enforcement actions that resulted in deferred or non-prosecution agreements (DPA or NPA) and legal issues. From this discussion you, the reader, should be able to understand the DOJ’s most current thinking on compliance issues.
Summing It All Up
The end highlights some of the top enforcement actions and compliance issues which companies have faced. These articles provide more than just “tea leaf” readings about where enforcement is going across the globe, and it will provide to you solid guidance for your compliance program going forward.
The book is available for the reasonable price of $19.99 and can be ordered from Amazon.com.
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