With the consequences of FCPA noncompliance ranging from “huge” to “catastrophic,” compliance should be top-of-mind for U.S. companies doing business with third-party intermediaries and subsidiaries overseas. In a conversation with Mimesis Law’s Lee Pacchia, Foley Partner David Simon discusses how companies should approach investigations to go beyond the “who,” “what,” “where,” and “when” to address the “why,” while 1) meeting U.S. government expectations for the investigation, 2) maintaining control of the investigation, and 3) reining in “scope creep.”
