FCPA Compliance Report

Excerpts from The Complete Compliance Handbook-Root Cause Analysis


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One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was the performance of a root cause analysis for any compliance violation which may led to a self-disclosure or enforcement action.

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FCPA Compliance ReportBy Thomas Fox

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