Gregory Millman – New York Times – January 22
For the most part, when it comes to compliance, government takes a “do as I say, not as I do” approach. Sentencing guidelines encourage companies to set up compliance programs by offering a chance of lower penalties when things go wrong, and settlements of enforcement actions often stipulate detailed enhancements for such programs. For example, announcing a recent settlement of bribery charges that cost Alcoa and a subsidiary $384 million, the Department of Justice noted that the company “has agreed to maintain and implement an enhanced global anti-corruption compliance program.”
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