Key Elements of Effective FCPA Remediation: Earning DOJ and SEC’s “High Premium”
The U.S. Department of Justice (“DOJ”) and U.S. Securities Exchange Commission’s (“SEC”) Guide to the U.S. Foreign Corruptions Act (“FCPA”) demonstrates, if there was any doubt, the importance of timely and effective FCPA remediation. Calling it a “high premium,” the DOJ and SEC explain that FCPA remediation can help an organization avoid criminal prosecution and enforcement proceedings; pay reduced penalties and safeguard brand value; and obviate a government-imposed compliance monitor or independent consultant.
In the Business Crimes Bulletin of Law Journal Newsletters, StoneTurn’s Jonny Frank and Rex Homme explain why it is not just the organization that is impacted by issues arising from poor internal controls.
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