An Effective FCPA Compliance Program Might Save the Company (A Great Defense Team Might Not)
“An Overview of the Organizational Guidelines” from the United States Sentencing Commission’s May 2004 release includes the following jaw-dropping statement:
… Continue ReadingCriminal liability can attach to an organization whenever an employee of the organization commits an act within the apparent scope of his or her employment, even if the employee acted directly contrary to company policy and instructions.