FCPA Compliance Report

Susan Divers on Evolution in Compliance over the Past Decade

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In this episode, I visit with Susan Divers, Senior Advisor at LRN. It is part of my continuing series this year looking back over the past decade of Foreign Corrupt Practices Act enforcement and the evolution of compliance. Some of the topics we consider are:

  1. How the heavy emphasis on enforcement by the DOJ led to organizations investing in compliance.
  2. How did companies begin to evolve their compliance programs away from paper programs, written by lawyers for lawyers?
  3. How the first industry sweep through energy led to a pragmatic business solution to compliance throughout the energy ecosystem.
  4. The DOJ evolution in communicating information on its expectations on best practices compliance program.
  5. The change in ERM emphasis requiring each company to manage its risks. 
  6. The use of data in compliance.
  7. Trends into the 2020s and beyond.

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    FCPA Compliance ReportBy Thomas Fox
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