The FCPA Blog | By: Fahira Brodlija | GPE – September 13, 2017:
The U.S. legal system doesn’t provide for an FCPA compliance defense, which would relieve a company of liability for FCPA violations if it can prove that it created and maintained an effective FCPA compliance program at the time the violation occurred.
The U.S. Sentencing Guidelines for Organizations do provide for the consideration of a reasonably effective compliance program when determining the penalties and fines in corporate enforcement actions. However, this does not remove liability from the company, nor does it have any remedial effects on the damage which occurs to their reputation through FCPA enforcement actions.
There are several reasons why introducing an FCPA compliance defense into the company’s toolbox would be beneficial both to businesses and also to the government.
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