An FCPA Compliance Defense? No Way, Breuer Says
April 1st, 2011
Wall Street Journal (Blog)
It’s a question that many in the compliance industry ask: why can’t the Justice Department and the Securities and Exchange Commission give crystal clear guidance on what a proper compliance program should look like?
The U.K. government, having passed and (finally) issued official guidance on the Bribery Act, has endeavored to do just that, promulgating six principles: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and monitoring and review.