By Daniel Levin – Partner at White & Case in Washington, DC
Companies lacking an anti-corruption compliance program face great legal, financial, and reputational risks. Government investigators will have no sympathy for those who fail to devote sufficient resources to compliance. Indeed, enforcement officials would certainly take the opportunity to make an example of companies that cut compliance resources in response to the financial crisis. Moreover, the trend towards prosecuting individuals—in addition to or rather than the company—is also likely to continue. But FCPA vigilance, like other forms of corporate compliance, need not break the bank in a time of budget constraints and cost controls.
The solution begins with a risk-based compliance assessment.