An article from Allen & Overy on 28 June asks what can companies learn from concluded enforcement actions in the past decade? It identifies –
· Beware insider risk;
· Bribes are usually disguised;
· A single corrupt transaction can be enough to attract prosecutor attention;
· Policies and procedures must be effective;
· Shore up the final defences; and
· Weigh up the pros and cons of entering into a deferred prosecution agreement.
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