Implementing Robust FCPA and Export Compliance Programs

Challenge

A global manufacturing company sought our guidance in developing and implementing comprehensive Foreign Corrupt Practices Act (FCPA) and export control compliance programs to mitigate regulatory risks and support their international expansion efforts.

Approach

Our corporate compliance team conducted a thorough assessment of the client's existing policies, procedures, and internal controls. We then developed a tailored compliance program that addressed the company's specific operational and geographic footprint, including the following key elements:

• Established a code of conduct and implemented robust anti-corruption policies aligned with FCPA requirements
• Designed export control procedures to ensure proper product classification, license determinations, and adherence to applicable regulations, such as the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR)
• Developed a comprehensive employee training curriculum to promote a culture of compliance across the organization
• Implemented ongoing monitoring and auditing mechanisms to identify and promptly address any potential violations

Result

Within 6 months, the client's FCPA and export control compliance programs were fully operational, earning praise from regulatory authorities. The programs enabled the company to:

• Expand into new international markets with confidence, securing necessary export licenses and approvals
• Avoid costly penalties and reputational damage associated with anti-corruption and export control violations
• Empower employees to make informed decisions and report potential issues through established reporting channels
• Demonstrate a commitment to ethical business practices and good corporate citizenship