45 · White collar defence and regulation · FCPA · Sapin II
FCPA/anti-corruption
What assistance changes in this practice, what it does not change, and the time reduction actually observed.
Where the gain is real
Third-party intermediary diligence, review of payments and expenses, country-by-country risk mapping.
Where it is slight or nil
Employee interviews, the decision to self-report, negotiating the resolution.
Observed time
−58% at constant case scope, on cases closed over the last three financial years. This measure says nothing about the quality of the outcome.
What the practice covers
- Diligence on intermediaries, agents and distributors
- Review of payments, commissions, expenses and gifts
- Risk mapping by country, subsidiary and process
- Review of the compliance programme and of the pillars required
- Anti-corruption aspects of acquisitions and of post-closing integration
- Preparation of the report and of the evidentiary annexes for the authority