Compliance Communications Blog

"Beyond Fines: Responding to Corporate Misconduct"


11/3/2015: If the threat of multi-million dollar fines isn’t enough to discourage corporate wrongdoing, what is? The question has swirled around since the DOJ ramped up its anti-corruption enforcement efforts. Billions of dollars have been returned to the federal purse but very few...corporate executives have been assigned orange overalls. In a post on the FCPA blog, Richard Bistrong draws on a New York Times op-ed by former assistant US attorney Eric Havian and, more importantly personal experience, to address the unfamiliar option of exclusion (also known as debarment). Bistrong’s willingness to highlight his own experience with exclusion gives compliance professionals an up-front view of an infrequently used enforcement approach that may become much more familiar. He deserves credit and the post deserves to be read.

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