ABSTRACT
Enforcement troubles start as soon as a suspected violation is internally detected (as represented in Figure 7.1) and continues until the case is resolved. Based on experience with the Foreign Corrupt Practices Act, resolution even after a voluntary disclosure can take up to 7 years! Given that adequate procedures and effective compliance ethics programs are likely to count for little when things have gone wrong, the lesson is to GET INTEGRITY RIGHT FIRST TIME and keep off the regulatory radar.
