Foley attorneys Mike Koehler and David Simon offer constructive analysis of the recent, record-setting Siemens FCPA action (White Collar Crime Report, February 27, 2009). Besides being of interest because of the size and scope of the action and the extent of the corruption in the company, they explain, the action teaches several important FCPA compliance lessons, including: (1) the FCPA’s broad reach; (2) the FCPA risks of utilizing third parties; (3) how FCPA compliance requires a committed ‘‘tone at the top’’; and (4) how FCPA compliance means more than just having a ‘‘paper program.’’
Reproduced with permission from BNA’s White Collar Crime Report, by The Bureau of National Affairs, Inc. http://www.bna.com.
