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Corporate Compliance Attorney Jim Bowers Analyzes New DOJ and SEC Guidelines on Foreign Corrupt Practice Enforcement

Publisher: Corporate Compliance Insights
January 3, 2013
Day Pitney Author(s) James E. Bowers

Veteran Day Pitney corporate compliance attorney James Bowers has written "DOJ and SEC Make Risk Assessment the Key to Compliance Effectiveness" for the Jan. 3, 2013, issue of Corporate Compliance Insights. The article outlines the steps companies need to take to ensure adherence to new enforcement guidelines issued by the Department of Justice and the Securities and Exchange Commission concerning the Foreign Corrupt Practices Act. The article lists effective compliance programs, compliance risk identification and assessment, regulatory environmental scans, gap analysis, and organizational assessment as crucial moves to avoid fines that have been "moving into the stratosphere." It also recommends "senior management set the right tone-at-the-top to ensure employee buy-in and ultimately good compliance behavior."

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