Michael Volkov – Corruption, Crime & Compliance – April 24, 2016
The FCPA Paparazzi have a thick head and a stubborn chin. They just do not understand the significance of Compliance 2.0 to corporate governance and they blindly adhere to simplistic, yet unexplained, solutions to complex problems – kind of sounds like a presidential candidate we all know.
Without getting into politics, which I avoid here on this blog, DOJ’s recent FCPA guidance on voluntary, disclosure, cooperation and remediation sets out an ambitious push on ethics and compliance programs. Of course, the new remediation elements apply only to those situations where companies are seeking cooperation and disclosure benefits, along with implementation of a remediation plan.
The new compliance elements represent validation of the Compliance 2.0 model, which has been advanced by leading compliance strategists, such as Tom Fox (here), Donna Boehme (here), Roy Snell (here), and Joe Murphy (here). Unlike many in the FCPA Paparazzi, they have been pushing new and innovative compliance strategies for years that flow from the elevation of an independent compliance function in global companies.
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