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As I eye my social media feeds, I see a stream of articles that provides a continuous repacking of enforcement actions, discussion about whom compliance should report to and much about ‘tone from the top’. Speaking of which, on the top or perhaps bottom of my anti-bribery reading list is a 42-page analysis of the recent Alstom Foreign Corrupt Practices Act (FCPA) settlement. Which is longer, I wonder, the analysis of the settlement or the settlement?
This article aims to raise organisational and strategic issues that need to be addressed in the context of corruption risk. If we want to address how to reconcile sales strategy with FCPA compliance, any effort that does not take into account organisational culture across divisions, locations and levels of seniority will never be ‘owned’ by the organisation. It cannot take root or succeed.