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Clifford Chance

Ten Hallmarks of Effective Compliance Programs for Asia Pacific Companies

Client Briefing

13 December 2012

Designing a corporate anti-corruption compliance program for companies operating in Asia Pacific sometimes feels like trying to fit a round hole around a square peg. No amount of pounding will smooth the edges off a thousand years of guanxi.

Fortunately, perhaps recognizing the impossibility of achieving a perfect compliance fit, U.S. regulators state “there is no one-size-fits-all program,” in their new Resource Guide to the U.S. Foreign Corrupt Practices Act (FCPA).

This briefing discusses the requirements set forth in the new FCPA Guidance and how to accommodate those requirements in light of the realities of operating in Asia Pacific countries.

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Ten Hallmarks of Effective Compliance Programs for Asia Pacific Companies

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