Good Practice

Top signs it’s time for an internal compliance investigation

STEPTOE: OUTSIDE COUNSEL

Export control and sanctions enforcers give credit to companies that self-initiate investigations, remediate breaches, and self-disclose violations of law in a timely manner. Sometimes, a compliance hiccup can be closed out with a light touch with no further investigation required. In other cases, a small mishap is a sign of a much larger problem, even a legal risk. When is it time to start digging? Here are three signs based on past investigations. 

1. Major...

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Jonny Test