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FCPA Month + Building a Better Program

on June 14, 2016

We’re unofficially calling June “FCPA month” here on the Oversight blog.  But why is FCPA compliance so important? In this piece on The FCPA Blog (which is one of our favorites and one we cite so frequently here at Oversight) it states that the Yates Memo, (or the DOJ’s Individual Accountability Policy) was one of the most impactful events for FCPA compliance, and one that companies should continue to be aware of as they’re building out compliance programs in 2016 and beyond.

Not familiar with the Yates Memo? Written and released in Fall 2015 it articulates changes to the Department of Justice’s policies that make it difficult for individuals to escape prosecution even when doing illegal business on behalf of their company. It also lays out that corporations may be able to partially absolve themselves of wrongdoing provided they are communicative, demonstrate an attempt at thorough compliance, and aid in the investigation.

Should an entire company really be fined (sometimes millions and millions of dollars) if they had no idea an executive was acting badly? Maybe not. After all, isn’t it difficult to keep up with one employee out of thousands?

Not anymore. By leveraging the power of Oversight’s Insights On Demand™ for FCPA solutions, companies can now audit all of your employee’s travel card spending for potential FCPA violations. The use of this technology not only makes this total visibility possible, but easier than ever before. 

After all, manual audits alone may not catch FCPA violations or vulnerabilities. Due to the sheer volume of transactions, it’s difficult to spot patterns of behavior. An FCPA solution such as Insights On Demand for FCPA is an important part of demonstrating an effective compliance program because it addresses several key DOJ guidelines for monitoring transactions.

Oversight loves talking FCPA. Here’s even more of our favorite posts from the blog: 

Why Guidance is Missing from FCPA Investigations
Find out how your company can create a culture where employees know that all transactions will be monitored automatically for policy compliance.

Avon’s FCPA Action and the Cost of Internal FCPA Controls
When the Avon FCPA penalty made headlines, we wrote a post estimating the makeup retailer could monitor their T&E for less than $100,000 per year even if FCPA monitoring were included.

3 Tools You Need for a Total FCPA Strategy
A preventive FCPA strategy takes the unknown aspects of self-disclosure off the table. 

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