Our dirty little secret, if this could rightly be called that, is that we practitioners vastly overstate the risk that the FCPA brings to companies. In-house Compliance officers have a good reason for it: we need to spur change. In order to get a corporation, especially a large multi-national corporation, to move you sometimes need a significant amount of pressure to overcome its inertia. Once you get things moving—that is, get budget, resources, and priorities—around the effort, momentum and positive inertia will keep you going.
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