Crash Landing: Lessons Learned from the FCPA Enforcement Action
Maurice Gilbert
Compliance Recruiter - Founding Partner Conselium at Conselium Compliance Search
Those complaining about the lack of Foreign Corrupt Practices Act (FCPA) enforcement activity can finally knock it off.
With the Dun & Bradstreet Inc. (D&B) declination in April, followed quickly by May’s enforcement action involving Panasonic Avionics Corporation (PAC) and its parent Panasonic Corporation (Panasonic), U.S. regulators at the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have roared back with not only significant enforcement actions, but more importantly for the compliance practitioner, important information about how the DOJ will consider enforcement actions under the new FCPA Corporate Enforcement Policy.
The new policy was announced last November, and it set the stage for the recent enforcements and offers reassurance to complainers. We've touched on this a number of times at Corporate Compliance Insights, often relying on the wisdom of Tom Fox, a regular and long-time contributor to our pages.
This month Tom explores Panasonic’s failings, while highlighting lessons the compliance practitioner can learn from this company’s misdeeds. Tom's insights can be found in a free download available now at CCI. We hope you'll read and share it. And be sure to subscribe to CCI for future updates on FCPA and other topics for compliance, risk and data privacy professionals.
Download the FCPA-Panasonic whitepaper at CCI