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Domestic Commercial Bribery
It would be difficult to exaggerate the attention in recent years dedicated to enforcement and compliance with the Foreign Corrupt Practices Act (FCPA). In contrast, domestic commercial bribery receives comparatively limited attention. While multinational corporations generally offer intensive FCPA compliance and training programs, domestic commercial bribery is often relegated to a sentence or two in a general business ethics policy.
This gap can put corporations in peril, and their advisers should consider expanding their anti-bribery initiatives to place greater emphasis on domestic commercial bribery.
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