Account

Sign in to access your account and subscription

Avoiding FCPA Liability by Tightening Internal Controls

Tightening up internal controls and putting in place an effective compliance program are crucial for lessening or even eliminating FCPA exposure -- and subsequent huge fines. The primary elements of an effective compliance program are discussed in this article.

30 minute read September 02, 2014 at 12:00 AM
By
H. David Kotz and Susan M. Mangiero
Avoiding FCPA Liability by Tightening Internal Controls

In early May of this year, Avon Products, Inc. (Avon) announced that it expected to pay $135 million to end long-standing federal probes of alleged violations of Foreign Corrupt Practices Act (FCPA) provisions relating to books and records, and internal controls.

This premium content is locked for LawJournalNewsletters subscribers only

ENJOY UNLIMITED ACCESS TO THE SINGLE SOURCE OF OBJECTIVE LEGAL ANALYSIS, PRACTICAL INSIGHTS, AND NEWS IN LawJournalNewsletters

  • Stay current on the latest information, rulings, regulations, and trends
  • Includes practical, must-have information on copyrights, royalties, AI, and more
  • Tap into expert guidance from top entertainment lawyers and experts

Already have an account? Sign In Now

For enterprise-wide or corporate access, please contact Customer Service at [email protected] or call 1-877-256-2473.

NOT FOR REPRINT

© 2026 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.

Continue Reading

Most firms are aiming their newest tools at the work they already do — pouring their most powerful technology into running the same tasks a little faster. But when everyone automates the same tasks at once, no one pulls ahead. That reaches the future a little faster while leaving a firm’s largest opportunity untouched — and that opportunity isn’t doing more of the existing work, but transforming how the high-value work gets done.

June 01, 2026

Artificial intelligence is rapidly embedding itself into legal workflows, but much of the conversation treats all use cases as if they carry the same level of risk, even if they do not. The more useful question is not whether AI works, but where it can be safely applied and where it cannot.

June 01, 2026