Chapter 7: Implementing a compliance program and effectively communicating compliance expectations
There is more to FCPA and related compliance than just spotting risk in a business organization. Think of this in terms of a sports analogy where a coach devotes hours studying an opponent to learn of its deficiencies and vulnerabilities. This is a great start, but the success of a sports team will largely depend on the ability of the coaching staff to implement a game strategy and effectively communicate it to the players who will be facing the opponent. The success of a business organization in minimizing risk under the FCPA and related laws likewise largely depends on implementing a compliance strategy and effectively communicating it to employees and agents in the global marketplace. Accordingly, Chapter 7 discusses how to implement written compliance policies and procedures throughout a business organization and effectively communicate the compliance strategy in a way that resonates with the intended audience. Next, training best practices will be highlighted (in terms of both who to include in training and how best to convey important concepts) as well as the importance of holistic compliance in which various corporate actors can play a meaningful role in minimizing risk.
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