In this blog post, Matteson Ellis discusses the emphasis that FCPA enforcement officials have repeatedly placed on two specific compliance areas: risk assessments and monitoring. Last year, Ellis says, officials "spent an inordinate amount of time talking about the 'bookends' of compliance; namely, (1) the risk assessments from which companies should design their compliance programs and (2) the monitoring and testing that should occur after implementation to ensure that the programs are implemented effectively." Officials "have repeatedly made it clear that they think these issues belong in the foreground of corporate compliance efforts. In case that message has not been received, there is an excellent chance that enforcement officials will be saying it again at this year's [ACI] conference," Ellis added.
This blog post initially appeared on the FCPAméricas Blog on December 23, 2014.