Practical Applications - FCPA

Practical Applications - FCPA


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Full video transcript available below:

So Practical Applications, I've titled this, especially for us in financial services. Obviously when an employee, when you're aware that they're meeting with foreign officials either overseas or if they're coming into your offices here in the US, you may want to if they're not particularly familiar with the rule or if they don't have a lot of experience with meeting with foreign officials, let's say someone visiting the US from a sovereign wealth fund, as an example, to your offices, it would be a good idea if before that conversation begins, if they just stop by compliance or legal, become fully aware of the firm policy, and have a conversation in terms of what they can do in terms of entertainment and all of that.

Gifts and entertainment policies, obviously employees should review that. The officers, sales staff, finance and accounting, market and business development, everyone comes into play here when we're dealing with foreign governments and foreign officials, right? So don't feel that maybe the marketing person doesn't need to be captured under these policies or rules. They do. Finance and accounting, they do. As I said, this rule is very broad based in terms of how the DOJ and SEC will go after individuals that fall under the rule, so we want to make sure that everyone is captured from an organizational perspective.


This webinar was co-hosted with MCG Consulting


Read our blog post: FCPA Fines in 2016 - Summary


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