Under the UK Bribery Act, if a corporation can show its compliance program meets [certain] criteria, it can avoid prosecution, even if employees break the law.
The chief of the Justice Department’s Criminal Division, Lanny Breuer, flatly rejected the need for a compliance defense in the U.S., saying “we can’t engage in some sort of formalistic solution from a script that says if you check the following six boxes you’re guaranteed this outcome.”
‘Enforcement 40’ for 2020
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