Fcpa Compliance Report

Beginning with the Department of Justice’s (DOJ’s) Yates Memo, its Foreign Corrupt Practices Act (FCPA) Pilot Program and then the release of the Evaluation of Corporate Compliance Programs (Evaluation), I believe the DOJ has put even more pressure on every Chief Compliance Officer (CCO), and indeed every company, to get an investigation done quickly, efficiently and most importantly done right is even greater.    Jonathan Marks, a partner at Marcum LLP and a well-known internal investigation expert, provides some of his thoughts around what goes into a well-run investigation. His perspective is from someone who performs investigations outside your organization, either because the matter was so serious an outside expert was required; specific subject matter expertise (SME) was not available in your organization or due to the objectivity of the investigation. Today I want to consider who should be on your investigation team.  As discussed previously data collection, retention and preservation are critical elem