Law360, New York ( April 15, 2013, 11:54 AM EDT) -- Virtually every authoritative source of guidance on effective anti-corruption compliance emphasizes the importance of conducting a companywide "risk assessment." For example, U.S. authorities have stressed with regard to the Foreign Corrupt Practices Act that "the assessment of risk is fundamental to developing a strong compliance program."[1] U.K. authorities have similarly emphasized the importance of risk assessments as an essential component of developing "adequate procedures" under the Bribery Act, noting that "the fuller the understanding of bribery risks an organization faces, the more effective its efforts to prevent bribery are likely to be."[2] The reasons for this are straightforward: To prevent a company's involvement in bribery and corruption, compliance measures need to be positioned in a way that addresses the forms such conduct is likely to take....
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