Glenn Agre partner Michael Bowen recently spoke with the Anti-Corruption Report about the recent executive order pausing enforcement of the FCPA and how corporations should react, if at all.
While the initial reaction was one of uncertainty, according to Mike, companies’ confusion has grander implications beyond just FCPA enforcement. He noted that: “The core idea of the FCPA is simple. Suspending or reducing enforcement suggests that the principles underlying the FCPA are up for debate or that it can be made subservient to prevailing political whim, which is the antithesis of the very idea of the rule of law.”
Given the risks companies continue to face despite the EO, experts advise maintaining the status quo with compliance programs. Mike stated that: “U.S. companies should not change their values, ethics, anti-fraud or ABAC policies,” and should “comply with the law as it has been traditionally understood and enforced.”
Read part one here and part two here (subscription required).