Late last year the SEC and the Department of Justice released A Resource Guide to the U.S. Foreign Corrupt Practices Act. The guide provides an analysis of the Act and examines the SEC and Justice Department approach to FCPA enforcement. See Joint Press Release. Among the issues discussed by the agencies were the hallmarks of an effective compliance program. In December, the D&O Diary featured a blog post suggesting active compliance monitoring involving monitoring and transaction testing. The failure to be proactive may lead not only to a FCPA violation, but also to a Sarbanes-Oxley certification violation. The failure to be proactive also leaves a company open to the "contagion effect," a risk highlighted by Quartz. Firms facing SEC or Justice Department investigation frequently expose the activities of competitors in an effort to appear cooperative. Contagion.
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