Why FCPA Compliance Software is important?
In recent years, the DOJ has increasingly used deferred prosecution agreements in FCPA compliance cases to provide a reward to defendants who voluntarily disclose and cooperate in the DOJ’s investigation. For example, York International and the DOJ entered into a three-year deferred prosecution agreement. This requires its compliance program and procedures reviewed by an independent monitor for three years. The DOJ agreed to defer prosecution in recognition of York’s implementation of enhanced compliance policies and procedures and its willingness to engage an independent monitor. A lot of the defence for a firm will depend on being able to demonstrate to the prosecutors that the firm has taken all reasonable steps to prevent this from happening in the first place. A key element of this will be implementing a monitoring programme which reviews and tests on a regular basis and records conclusion along with test result data. You could do this manually, however using the right system coul
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