The cost of doing nothing: Mitigating FCPA risks (Part 3)

Erin Giordano | 06-22-2017

According to Foreign Corrupt Practices Act (FCPA) expert Mike Koehler, who runs the award-winning FCPA Professor website, “2016 witnessed the largest number of corporate enforcement actions and the largest aggregate corporate settlement amounts in the FCPA’s nearly 40 year history.

“There were 27 corporate enforcement actions resulting in approximately $2.3 billion in settlement amounts,” says Professor Koehler. “In the words of Trump administration officials, the Department of Justice remains committed to enforcing the FCPA."

Companies are doing their best to follow best practices and developing and enforcing compliance programs to minimize the risk of FCPA violations.

However, companies with more experience and insight have learned that while mining travel and expense data is valuable, even more so is ensuring compliance teams leading the charge in companies are proactively meeting with those who oversee both travel and expense reimbursement within the organization to uncover better ways to mitigate this risk.

Savvy companies are modernizing their policies and procedures as as team. Also, they are using solutions that they can cleverly configure to manage employee and manager behavior, easily aggregate data from multiple sources - such as credit cards, hotels, taxis, short-term housing suppliers, and pull reports quickly to help identify suspicious spending, individuals or behavior.

 

To learn more about best practices for minimizing FCPA risks:

Download this executive summary that highlights key points from an educational webinar held on Wednesday, July 12, led by Professor Koehler.  This session explored recent FCPA enforcement actions based on corporate hospitality and compliance take-away points from those actions. Also, former practitioner and now Sr. Functional Consultant at Concur, Lacey Hughes,  shared some real practices companies are taking today to mitigate this risk within their T&E programs. 

 

Previously: The cost of doing nothing: Tax troubles for guestimators (Part 2)