Updates on 2016 Anti-bribery cases - Good article
2016 Anti-Bribery Cases—The Year of Internal Controls, Books & Records By Kristin Casler, featuring Gregory Husisian of Foley & Lardner LLP and Michael Volkov of The Volkov Law Group LLC Years of robust federal enforcement have convinced most companies operating internationally to initiate policies that forbid outright bribery of foreign officials. That would have been sufficient in the early days of the Foreign Corrupt Practices Act of 1977, when corporate compliance generally hinged on the existence of any kind of compliance program. Over the years, though, minimum standards have evolved to require a corporate compliance program be more than just a “paper program”— it needs to be “effective.” Now, the latest Department of Justice and Securities & Exchange Commission cases indicate another escalation—companies must also have good, functioning internal controls. That means companies must take utmost care with foreign transactions and dealings in countries known for c...