The “Human” Side of FCPA Compliance: How to Best Work With HR in the Current Global Enforcement Environment

Coordination between the compliance department and the human resources department helps ensure the best outcome in the case of corruption-related misconduct. A cross-functional approach allows the company to receive maximum cooperation credit while satisfying local labor and data privacy law requirements and meeting employee expectations. Further, the HR department can play an important role in preventing anti-corruption violations in the first place. In a guest article, Paul, Weiss partner Alex Oh and former senior compliance attorney Kim Vinocour explain the practical implications of DOJ guidance and enforcement actions for corporate compliance and HR departments, focusing on hiring decisions, internal investigations and corruption-related disciplinary actions. See The Anti-Corruption Report’s three-part series on the DOJ’s FCPA Corporate Enforcement Policy: “What’s New and What’s Not” (Jan. 10, 2018); “How Important Is the Presumption of Declination?” (Jan. 24, 2018); and “Cooperation and Compliance Expectations” (Feb. 7, 2018).

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