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.
‘Enforcement 40’ for 2020
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