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'Red Flags and Iceberg Tips'

Congress and the Department of Justice (DOJ) are driving home an important point: A company's central management is ultimately responsible for any criminal conduct by its business divisions and employees, and must therefore implement policies and procedures to ensure that it promptly discovers and corrects any potential violations.

20 minute read August 18, 2003 at 12:33 AM
By
Ira H. Raphaelson, Alan M. Cohen And Jeremy Maltby
'Red Flags and Iceberg Tips'

Congress and the Department of Justice (DOJ) are driving home an important point: A company's central management is ultimately responsible for any criminal conduct by its business divisions and employees, and must therefore implement policies and procedures to ensure that it promptly discovers and corrects any potential violations.

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