Fcpa Compliance Report

One of the things that I learned from the television series M*A*S*H was the need for triage. In the hospital setting, triage is the process of determining the priority of patients’ treatments based on the severity of their condition. This is considered in different language in the Justice Department’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation), which under Prong 7 reads, in part, Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly scoped, and were independent, objective, appropriately conducted, and properly documented? Tying all of together is short but succinct statement found in the 2012 FCPA Guidance, “once an allegation is made, companies should have in place an efficient, reliable,  and properly funded process for investigating the allegation and documenting the company’s response, including any disciplinary or remediation measures taken.”  Given the number of ways that information about violations or potential