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Enforcement of the Foreign Corrupt Practices Act (FCPA) remains vigorous and has recently targeted more individual corporate representatives than ever before. The U.S. government’s response to the high profile Morgan Stanley and Ralph Lauren matters demonstrates that effective compliance and self-reporting can actually serve as a shield against criminal and civil prosecution. It has long been a maxim that a proactive compliance program provides companies with significant benefits, both external and internal. It is now apparent that the government expressly considers whether a company maintains a robust compliance program in determining whether to bring criminal and civil charges for violations of the FCPA.