A post on the FCPA Blog on 8 June commented on the use of these arrangements which, like US DoJ Deferred Prosecution Agreements, seek to change the behaviour of businesses, as well as debarring them from bidding for contracts.  It explains that, since late 2010, a company can contract to agree to institute (or improve) and effectively implement a corporate compliance programme in exchange for a reduced penalty or term of debarment.  The author of the post was an Integrity Compliance Officer for the World Bank Group.



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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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