You have just been named General Counsel of a new public company. Perhaps you got the job because you are a corporate lawyer who worked on the offering, a litigator who successfully handled a case that made the offering possible, or maybe a friend of the CEO. In any event, you probably didn’t get the job because of your experience in dealing with criminal wrongdoing within a corporation. Your lack of experience in this area can be a disaster for your company, its management and you – and your instincts alone may not be enough to steer you right.
Let’s take a case in point. After a year of steadily increasing revenues, you hear through the grapevine that some of those revenues may be tied to illegal payments made abroad in violation of the Foreign Corrupt Practices Act. You file the information away, hoping nothing comes of it. Nothing does, until federal marshals show up at your office with a subpoena or a search warrant, at which time you learn that the government received the
