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Jan 06

It’s All About the Culture . . . and Committing the Resources to Protect It and Yourself

Christopher Scott D’Angelo, MMWR Partner and Chairman of its International Practice, recently wrote an article published in the Pharmaceutical Compliance Monitor about the importance of creating and maintaining a culture of compliance within a company. He emphasizes the benefits of such efforts in light of the increased risk of enforcement actions for violations of the Foreign Corrupt Practices Act, and other enforcement actions for violations of other country’s similar anti-corruption laws. We have recently written about the successful convictions by Britain’s Serious Fraud Office under the UK’s Bribery Act of 2010, and how the SEC sanctioned two former defense contractors, Stephen Timms and Yasser Ramahi, for violating the Foreign Corrupt Practices Act by taking Saudi government officials on a “World Tour.”

Mr. D’Angelo is well-versed in advising corporate clients about these issues: part of his practice includes representing foreign concerns in the United States and United States concerns abroad. As he notes, the DOJ has publicly pronounced that “fighting global corruption was, and would continue to be, a core priority of the Department of Justice.” Companies should recognize that they operate within this atmosphere of heightened attention to such issues, and that now is the critical time to ensure that proper training prevents possible problems down the road. Mr. D’Angelo argues that effective training, though, isn’t just telling people what they can’t do but also includes enforcing company expectations for compliance-minded decisions, encouraging people to make the right decisions, and creating the proper channels for company assistance and support when the right decisions aren’t made.

Please read the full article here.


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