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From Baksheesh to BriberyUnderstanding the Global Fight Against Corruption and Graft$
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T. Markus Funk and Andrew S. Boutros

Print publication date: 2019

Print ISBN-13: 9780190232399

Published to Oxford Scholarship Online: May 2019

DOI: 10.1093/oso/9780190232399.001.0001

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PRINTED FROM OXFORD SCHOLARSHIP ONLINE (oxford.universitypressscholarship.com). (c) Copyright Oxford University Press, 2020. All Rights Reserved. An individual user may print out a PDF of a single chapter of a monograph in OSO for personal use. date: 29 November 2020

Corporate Monitors and the Monitorship Process

Corporate Monitors and the Monitorship Process

(p.617) 24 Corporate Monitors and the Monitorship Process
From Baksheesh to Bribery

Andrew Boutros

Oxford University Press

The prospect of a Foreign Corrupt Practices Act monitor is an unpleasant one for a company that just emerged from what likely was a long, expensive, and invasive investigation and wants to get back to business. A compliance monitor brings even more cost, effort, and scrutiny through evaluating the company’s anti-corruption compliance program, conducting interviews, performing testing, and making recommendations. Although rarely welcomed by companies, a well-executed monitorship can be a helpful endeavor that results in a stronger company. This chapter discusses the use of corporate compliance monitors as a condition to resolving corporate FCPA enforcement actions, common aspects of FCPA monitorships, and best practices for achieving a successful FCPA monitorship.

Keywords:   compliance, corruption, DPA, FCPA, monitor, monitorship, NPA

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