How Morgan Stanley's effective anti-corruption risk
management and compliance framework helped avert regulatory
action
Introduction
Continued enforcement of the US Foreign Corrupt Practices Act
('FCPA'), coupled with the introduction of the UK Bribery
Act ('Bribery Act') and proposed tightening of the
provisions for foreign bribery in the Australian Criminal Code mean
that bribery and corruptions is a topic that will not go away.
In this article, Jarrod Baker discusses a recent FCPA case
development that highlights the benefits of being proactive and
developing a robust anti-corruption risk management and compliances
framework.
Why you need to take this seriously
An Australian company can be fined at least $11 million under
the Australian Criminal Code for the offence of bribing a foreign
public official (i.e. the company may be liable for an act of
bribery committed by an employee or someone acting on the
company's behalf, regardless of whether they are
