Search Our Website:
Matthew J. Feeley, Shareholder in Buchanan Ingersoll & Rooney’s Litigation Section, wrote a chapter that was published in the 2013 Edition of International White Collar Enforcement. Feeley’s chapter was titled, “Key Components of the Newly Issued FCPA Guide and Best Practices for an Effective Compliance Program.” The chapter provides a resource guide to the US Foreign Corrupt Practices Act, including the definition of “foreign official,” as well as discussions of facilitation payments, successor liability, compliance programs, declinations and self-reporting of FCPA violations. The chapter also focuses on multiple best practices for establishing an effective compliance program, such as commitment from senior management, a clearly articulated policy against corruption, and third party due diligence and payments.