1. Corporate Governance Failures And FCPA Violations

    Corporate Governance Failures And FCPA Violations

    Whenever I read about the latest enforcement action – whether it is FCPA, export controls and sanctions, health care fraud, off-label marketing, or False Claims Act – my first question is always what role, if any, did the board of directors’ play in the compliance failure? The buck starts and stops with the board of directors.  Compliance meltdowns do not occur unless the board is complicit by action or inaction.  If a board fails to exercise its duty of oversight, it is likely that officers and

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