The Board’s Role in FCPA Compliance

Board oversight of FCPA compliance entails understanding a company’s risk profile, compliance program and best practices, and questioning and testing whether a program is fit for purpose and being implemented consistently by management, explained Kathryn Cameron Atkinson, a member at Miller & Chevalier, at a recent Strafford seminar. She and Jay G. Martin, senior counsel at Willkie Farr & Gallagher, analyzed the common law standards and regulatory duties imposed on boards as they relate to compliance oversight and discussed how a board can ensure compliance program effectiveness. We distill their insights. See “Board Responsibility for Ethics and Compliance” (Jun. 15, 2016).

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