On July 3, the Criminal Division of the Department of Justice and the SEC released the 133-page Resource Guide to the US Foreign Corruption Practices Act, Second Edition. This reiterates that a “one-size-fits-all” or “check-the-box” approach to compliance will not be successful in combatting bribery or corruption, and will not be looked favorably upon by enforcement agencies. Compliance programs must not be static and must adjust, especially when high-risk parties are identified. With that in mind, Steele Compliance Solutions Inc., in its role to assist companies in preventing corruption, has identified key updates and takeaways from this guide.
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Compliance Week: Additional Tips for Success in Combatting Bribery and Corruption
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