One of the lessons we have learned from various FCPA enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. Whether a corrupt employee is working to actively hide a pot of money, which can or will be used to pay a bribe, or an improper payment slips through the cracks, complexity can work to defeat a best practices compliance program. A compliance function needs visibility into a business unit, how it does business, and where its payments are going, or else it may be due See more + One of the lessons we have learned from various FCPA enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs.

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