The next step is to follow through on FCPA compliance. Shah cautions that many companies develop plans but don’t implement them well.
“The problem I see the most is that companies don’t audit their compliance program or they audit it ineffectively,” says Shah. “We’ve been to companies that have compliance programs, but the folks on the ground are not taking it beyond a basic internal audit when it’s really about drilling down and getting specific. Within these high-risk areas, which accounts have been troublesome in the past? Look at those.”
The overall objective is to make sure that all employees around the world understand the need for FCPA compliance. That’s important not only to the bottom line but to the brand’s future. And increasingly, it will be important to executives who could find themselves in court if they fail to take this law seriously.