“Institutionalizing effective compliance is like getting your oil changed — unexciting, and with results that cannot be easily seen. An internal investigation, however, is the engine seizure that occurs after the lack of routine maintenance — exciting, perhaps, but costly.”
Recent headlines are starting to bear out what white collar attorneys have known for years: U.S. control of international conduct is skyrocketing, and the battleground is widening. While FCPA and antitrust enforcement actions will continue to be the U.S. government’s main focus, companies now need to institutionalize effective compliance to address anti-money laundering regulations, OFAC economic sanctions, and ITAR and EAR export controls.
In this white paper, Foley Partner Scott Fredericksen discusses his experience as a corporate monitor —an independent institution appointed by the U.S. government to review ongoing compliance obligations generally imposed by large settlements. Topics include learning from settlement agreements and compliance lessons learned as a monitor.
This white paper was first published in International Trade Law and Regulation, Volume 21, Issue 3, April 2015 (Thomson Reuters).