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Establishing Credibility with FCPA Enforcement Officials

Corporate Compliance Insights

In this article, Matteson Ellis describes strategies that companies can follow to establish and maintain credibility with enforcement officials when under investigation for FCPA violations. Ellis said companies and their executives can sometimes find it hard to accept when they are under investigation for potential violations. "When companies learn that liability may be civil and criminal, may involve both corporate and individual liability and certainly implicates significant cost and reputational considerations, the effects can be overwhelming," Ellis said. He added that establishing a plan at the outset, following internal investigation best practices, moving quickly, maintaining honesty and striking the right balance between cooperation and advocacy are key steps for achieving the best possible outcomes.