Day 9 of One Month of Innovation in Compliance - a podcast by Thomas Fox

One of the key things the Department of Justice (DOJ) has consistently communicated is the importance of operationalizing rather than having a paper compliance program in place. The Department of Justice’s Evaluation of Corporate Compliance Programs (Evaluation) made clear that to receive credit in any Foreign Corrupt Practices Act (FCPA) enforcement action, you must fully operationalize your compliance program in the remediation phase. 
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