Earlier this year, two senior executives frustrated with the high customs duties imposed on their imports into Haiti took matters into their own hands. They paid off a few Haitian officials.
Building A State- of-the-Art Anti-Bribery Program
Anti-bribery laws have serious consequences for ordinary companies doing business internationally. Violations come to light during routine M&A due diligence, when competitors complain or employees blow the whistle, or when companies voluntarily disclose as a part of their Sarbanes-Oxley reporting obligations. When they do come to light, strong internal controls may shield executives from some liability and restore confidence amongst shareholders and regulators. <br/>To mitigate the risk arising out of events like these, every company operating internationally should have a compliance program. The critical elements of a robust program are clear. With the right combination of leadership, training, and follow-up, companies can increase their chances of preventing or catching employees determined to break the law. An effective anti-bribery program need not be expensive or labor-intensive, but it does require management commitment, a systematic roll-out, widespread training, and diligent follow-up.
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Alexandra A. WrageThis premium content is locked for LawJournalNewsletters subscribers only
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