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James Tillen and Marc Alain Bohn Quoted on Impact of Regime Change on Corruption Investigations in FCPA Compliance Report

Subtitle
"Lily Rosemary and the Jack of Hearts and Surviving Regime Change"

FCPA Compliance Report

James Tillen and Marc Alain Bohn* were quoted on the effects of democratic regime change on corruption risk for companies. Tillen believes regime change is an opportunity to encourage companies to conduct a risk assessment to evaluate contacts with the prior administration or regime, and the associated risks. When there is a regime change, it is "definitely time to reevaluate, to consider whether your safeguards are effective, consider the exposure that may come from scrutiny on a local partner or a third party. From there you should next consider whether you need to make any changes as a result," Tillen said. Bohn added that conducting business in a transparent manner is one of the most important things a company can do. "You can never avoid risk," Bohn said. "I think it's hard to predict what's going to occur in some of these situations, but you're going to position yourself as best you can to weather that regime change."

*Former Miller & Chevalier attorney