DOJ and the SEC to U.S. Businesses: We Expect Action on Effective Compliance Programs
Based on my experience as a U.S. Attorney, I see the new joint Department of Justice (“DOJ”) and Securities Exchange Commission (“SEC”) Resource Guide to the Foreign Corrupt Practices Act (“FCPA”) as a game changer that presents important opportunities for clients with an international footprint. The message from Lanny Breuer at DOJ and Rob Khuzami at the SEC should be loud and clear: it is time to examine and improve your compliance plan because the government wants U.S. businesses to lead the charge in defeating foreign corruption by effective internal efforts and for those who don’t heed the call, there will be consequences.
This article was originally published in Lane Powell’s D&O Discourse blog.
For more information, please contact the Foreign Corrupt Practices Act, Bribery and International Anti-Corruption Practice Group at Lane Powell: