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In facing anti-bribery and anti-corruption (ABC) challenges, with new layers of ABC legislation being introduced globally, compliance teams—especially those working with international companies—are dealing with ever-increasing regulatory complexity and diversification. Intensifying enforcement focus on corporate wrongdoing in a growing number of jurisdictions means that compliance officers are facing increased levels of scrutiny from regulators and criminal enforcement authorities. In light of this new environment, as well as recent enforcement actions against senior compliance officers, part I of this article provides a brief overview of the state of play of the criminal enforcement risks for compliance officers as well as some of the implications—both practical and legal—for companies and their compliance departments in the U.S., France and the Netherlands. Part II will follow up with the UK, Germany and Ukraine, finishing off with takeaways based on the developments discussed in relation to all six jurisdictions.

U.S.: Continued Action Against Compliance Officers, Particularly in the Financial Sector

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