Dozens of multinational corporations are being investigated for alleged bribery overseas, and recent allegations that Wal-Mart's Mexican subsidiary engaged in a "campaign of bribery" have put the FCPA back into the spotlight. In the wake of the Wal-Mart allegations, Paul Enzinna and Lauren Curry of Brown Rudnick discuss the importance of an effective, robust compliance program -- a company's first line of defense in preventing bribery overseas, and a critical factor in attempting to mitigate any sanctions for FCPA violations. The program will also discuss:
- The need for collaboration between in-house and outside counsel when a company faces potential FCPA violations:
- Essential steps that should be taken after receiving reports of potential Foreign Corrupt Practices Act (FCPA) violation, including a thorough and independent internal investigation
- The role of in-house counsel in working closely with outside counsel in conducting such an investigation, and determining whether self-disclosure is appropriate
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