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Strategies for Minimizing Risk Under the Foreign Corrupt Practices Act and Related Laws

Mike Koehler

In the minds of some, complying with the US Foreign Corrupt Practices Act and related laws such as the UK Bribery Act is easy: ‘you just don’t bribe’. The reality, as sophisticated professionals know, is not so simple. This book is for professionals across various disciplines who recognize the difficulties of compliance and want to learn strategies for minimizing risk under aggressively enforced corporate bribery laws. The book uses issue-spotting scenarios to present risk and guides professionals through various components of compliance best practices from the fundamentals of conducting a risk assessment and effectively communicating compliance expectations, to implementing and overseeing compliance strategies.
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Chapter 8: Overseeing a compliance program

Mike Koehler

Extract

Prior to Chapter 8 you will have: (i) learned why spotting risk under the FCPA and related laws is an important skill for a diverse group of professionals; (ii) constructed your own “FCPA goggles” through an element-by-element review of the FCPA’s provisions; (iii) practiced wearing your “FCPA goggles” through issue-spotting scenarios; (iv) learned of various sources of compliance best practices and the common elements found in these sources; (v) conducted a risk assessment of a real company based on generic information; and (vi) learned of various best practices to implement a compliance program and effectively communicate compliance expectations within a business organization. These are all critical tasks to minimizing risk within a business organization. However, a compliance professional’s job is not yet finished as this chapter highlights various risk management strategies relevant to oversight responsibility and resources for a compliance program; having a system for internal reporting of compliance concerns and proper investigation protocols; and finally the important step of periodically assessing a compliance program and continuous improvement.

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