Consider the Herbalife FCPA enforcement action a case study in why multiple redundancies are important. Unless the whole of the organization is corrupt, eventually someone will notice misconduct and compliance violations. In Herbalife’s case, the company’s bribery scheme spanned 10 years and stretched right to the top of the organization.
Tom Fox mines the Herbalife FCPA enforcement action for lessons learned and explores where FCPA enforcement might be headed.
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