Traditionally, the role of a judge in reviewing an agreement to resolve civil or criminal charges has been very limited.
The list of industries and business sectors that must direct their compliance professionals to consider FCPA and anti-bribery laws in their business conduct and compliance programs has both expanded and evolved.
They all start differently. Sometimes an employee blows the whistle regarding a potentially problematic internal practice. Other times, a subpoena arrives from a government agency or the FBI arrives unannounced. No matter how it starts, it is time to face reality: You are about to begin an internal investigation.