FCPA Compliance Key – Mapping Players to Transactions

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Having supported far too many FCPA investigations over the last 30 years, the hardest initial step is untangling the key employees, contractors, agents and foreign players involved in doing business overseas. The TGC article provides a solid checklist for compliance defensibility that many corporate clients would shy away from because of the heavy manual overhead required. Most enterprise content management systems now include categorization/tagging systems. These require an up front investment to build the relationships between global HR, transaction, contract, communication and other systems to automate associations and tracking. This can be the key to minimizing the compliance and incident response efforts required. Moreover, automated alerts and random sample reviews carry a lot of weight with investigators and the bench when defending the company’s efforts.

Written by Greg Buckles

Independent consultant focused on eDiscovery and IG solutions.

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