The last several years have seen an explosion of enforcement activity surrounding the Foreign Corrupt Practices Act (FCPA) as regulators work to combat corruption. Statements by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC)—the agencies responsible for enforcement of the statute–indicate that this trend is expected to continue. Of particular concern to the DOJ and the SEC is whether companies are properly “vetting” their third-party business partners to ensure that those individuals and entities are not violating the FCPA in their activities on the company’s behalf and thereby subjecting their business partners to liability. Joe Spinelli and Jay Perlman of Navigant address a risk based approach to FCPA compliance by leveraging technology.
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