From the DOJ’s dismissal of its FCPA case against a pair of tech executives to its recent announcements that some other FCPA cases will continue to state enforcers reminding everyone they can issue charges, too, the past several months have been a challenge for professionals trying to mitigate risk amid the DOJ’s pause on FCPA enforcement. But now is not the time to back down from smart and effective compliance practices regardless of whether they originated out of concerns over potential FCPA violations; in fact, it may be wise to double down, experts told CCI contributing reporter Esther D’Amico.
Even if compliance officers already have sound practices and procedures in place to avoid risk, they “should be worried about how people are interpreting [the DOJ’s FCPA enforcement pause],” said Frank Orlowski, a managing director at Alvarez & Marsal, whose experience includes implementation of FCPA controls remediation and certification programs.
Crystal Jezierski, senior managing director at consultancy Guidepost Solutions and a former compliance executive with government and private sector experience, agreed. They should be worried about employees “letting their foot off the gas” and not paying as close attention to compliance as they used to, she said.
“My fear would be that people…
