Leslie Caldwell, chief of the DOJ's criminal division, talked at last week's Annual Ethics and Compliance Conference in Atlanta. She covered the ten hallmarks of an effective compliance program and cooperation with the DOJ in FCPA and other white-collar investigations. Her examples of good and bad corporate behavior came from real life.
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Avon Products Inc. said it could pay as much as $132 million to settle an ongoing investigation into whether it paid bribes in China and other countries in exchange for government permits it needed to open new markets.
The theme of this year's FCPA reporting, detection and enforcement activity is that the bribery of foreign officials is not something the public will tolerate or the U.S. government will trivialize.
It is also something businesses can and must create mechanisms to prevent.