It’s Not About Perfection
Perfection is not possible … imperfection is not an excuse
The recently updated guidelines to the United States Foreign Corrupt Practices entitled A Resource Guide to the U.S. Foreign Corrupt Practices Act (November 2012) offers myriad helpful principles, case studies, and clarifications to facilitate compliance and proactive engagement with the authorities on various issues potentially covered by the FCPA. However, perhaps the most useful and reassuring guiding principle appears late in the document in Chapter 5 “Guiding Principles of Enforcement”: neither the Securities and Exchange Commission (SEC) nor the Department of Justice (DOJ) seek perfection. Nor should you. Read more →