- FCPA Professor - http://fcpaprofessor.com -

The Results Are In …

A couple of survey/poll results that may be of interest to FCPA followers.

The first survey is courtesy of Deloitte which obtained over 1,000 on-line survey responses from business professionals in various industries in connection with a recent webcast titled “Global Anticorruption: Risks and Strategies for Today’s Global Enterprise.”

Results of interest:

Only 31% of respondents indicated that their company had in place a “comprehensive FCPA compliance program.” When asked why some companies might not have a comprehensive FCPA compliance program, 23% of respondents cited an “unawareness of the severity and consequences of FCPA violations.” Clearly more people need to read this blog (and others) and follow FCPA news!

Only 32% of respondents indicated that their company addresses FCPA risks “proactively.”

Respondents are most nervous about FCPA issues arising from: foreign subsidiaries (35%), agent/consultant relationships (28%) and joint venture/strategic alliances (18%).

And finally, 40% of respondents either said “no” or “don’t know” to the question of whether the increased FCPA enforcement activity will deter future FCPA violations. You have to wonder what goes through the minds of Mark Mendelsohn and others at DOJ when they read a response like that?

The second survey (see here [1]to download) was sponsored by Integrity Interactive Corporation and Compliance Week. The survey (which covers a wide range of compliance and ethics topics – not just the FCPA) collected approximately 230 responses from executives at global public companies and large private entities. Pgs. 38-39 of the survey contain FCPA data and indicate that executives are most concerned about payments to third parties, followed by inappropriate gifts and entertainment, direct bribes, company-financed “business trips” and unlawful political or charitable contributions.