THE MAGAZINE

Due Diligence Across Borders

By Ann Longmore-Etheridge

“If the company gathers the facts as much as it can and says, for example, ‘Look, we bought this other company, then we found out that these business lines have some issues, and we’re investigating that; we’re enforcing our compliance policy,’ then it is on much more solid ground,” he says. The action may not preclude the company from being investigated by law enforcement or from being penalized because it may have reaped the rewards of the corrupt activity; however, it may soften the enforcement action against the firm.

“There’s some argument that most of the countries putting laws on the books don’t have the teeth or the investigative resources to act to pursue anticorruption, but that is changing, and I think the global culture is coming around to say that corruption is not good, and it’s not helping anybody,” says Runyan.
 

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