Recommendations For A Firm Wide Fcpa Compliance Program

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TRIMART USA (LLC) MEMORANDUM FROM: In-house Legal Our Ref: HH/ADM/INHL/10 TO: Chief Executive Officer Date: April 15, 2015 RE: MR EDWARD’S SUIT With reference to your memo on 10th march, 2015, on the above subject matter and our earlier discussions on it. I wish to make the following recommendations: Recommendations for a Firm-wide FCPA Compliance Program There is no one-size-fits-all compliance program, since no two companies are alike and no two companies’ face the same issues internally and externally. It is essential that each company designs its compliance program. However, most deferred prosecution agreements and settlements and decisions…show more content…
Due Diligence A program of ongoing due diligence for past, present and proposed company activities is one of the pillars upon which an effective compliance program is built. If a potential business deal comes under suspicion, or if a due diligence investigation discloses suspicious circumstances, the US party must resolve it or face possible serious consequences . Relevance and Risk Assessment The program must be relevant to the company and its operations. Because risks differ in type and size from country to country, and because no two companies are the same, a compliance program requires advance analysis of the risks of the industry sectors, analysis of the country and the region, size of the business and size of the company, type of company’s products and activities, level of interface with government officials, quality of contractors, agents, distributors and partners, red flags, and corporate code of conduct . Designed to provide a big picture of your overall compliance obligations and then identify areas of high risk so that you can prioritize your resources to tackle these high risk areas first Training and Certification Education is one of the key elements of an effective compliance program. This process must require all persons to attend presentations/seminars and to provide adequate profit they understand what is being taught to them. The in-house procedures for investigations and for dealing
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