Role of Apology in Anti-Corruption Efforts

February 13, 2014

Thomas Fox, creator of the widely followed FCPA Compliance and Ethics Blog, was inspired by #ApologyWatch and wrote a thoughtful blogpost that asks several probing questions about what it means to truly apologize in the wake of an FCPA violation. I often use what I characterize as McNulty’s Maxims on questions that would be asked by a regulator in any Foreign Corrupt Practices Act (FCPA) enforcement action: (1) What did you do to prevent it?; (2) What did you do to detect it?; and (3) What did you do […]