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The role of the CCO has steadily grown in stature and prestige over the years. The 2020 FCPA Resource Guide, under the Hallmarks of an Effective Compliance Program, focused on whether...
On January 17, 2023, Assistant Attorney General (“AAG”) Kevin Polite announced revisions to the Department of Justice’s (“DOJ”) Corporate Enforcement Policy (“CEP”), which will apply to...
The US Department of Justice (DOJ) continues to try to dispel lingering skepticism over the benefits of corporate disclosure and cooperation. In remarks delivered on January 17,...
As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The 2020 Update devotes an entire prong to third-party management. It begins...
What are internal controls? The best definition I have come across is from Jonathan Marks, who defined internal controls as: Internal control is an action or process of...