To best manage and minimize Foreign Corrupt Practices Act risk, it is important that a business organization not view FCPA compliance as strictly a legal function, but rather a function best achieved holistically throughout the organization. This requires business managers, including finance and audit professionals in particular, to have the skill-set to recognize FCPA risk.
It is clear from recent FCPA enforcement actions that the enforcement agencies, and the SEC in particular, expect much from business managers when it comes to FCPA compliance including the ability of these gatekeepers to spot FCPA issues and display a high degree of intellectual curiosity as to many company transactions and expenditures. (See enforcement actions here, here and here).
This free video (created in collaboration with Emtrain with whom I’ve created a global anti-bribery and corruption training course) has been created to help business organizations best mitigate FCPA risk. Feel free to share the video with clients, in-house counsel and other compliance professionals, and business managers within your organization.