ABSTRACT
All companies with even the slightest connection to the USA must take great care over their control and compliance programmes in what is an extremely comprehensive, complex and ever-changing regulatory environment. There are 52 separate judicial systems in the USA1 concerned with fraud and bribery,2 each with its own State and local enforcement arms. In addition the US Attorney General has offices in over 90 districts with heavyweight investigatory teams: all bristling with lawyers turbocharged with testosterone.
