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Understanding the FCPA - ACC.com

Understanding the FCPA - ACC.com

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<strong>FCPA</strong> Compliance<br />

Three Elements:<br />

Robust corporate <strong>com</strong>pliance program<br />

Due diligence for particular transactions and<br />

relationships<br />

Prompt response to violations, or indications<br />

of a violation<br />

The government will consider each of <strong>the</strong>se<br />

elements in evaluating whe<strong>the</strong>r or not to bring an<br />

enforcement action<br />

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