Fine-Tuning Your Corruption Risk Management
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Board Perspectives: Risk Oversight, Issue 42 - How Morgan Stanley Avoided FCPA Enforcement Action: 10 Compliance Lessons from the DoJ Opinion Release
Last year, a former Morgan Stanley managing director pleaded guilty for his role in a conspiracy to evade the company’s internal accounting controls and violate the U.S. Foreign Corrupt Practices Act. This case is significant because the U.S. Department of Justice (DoJ) declined to bring enforcement action against the executive’s employer.
The DoJ’s references to Morgan Stanley’s compliance practices in its opinion release provide an insightful benchmark for companies in all industries to use in evaluating their compliance practices.
Issue 42 discusses 10 lessons learned from the DoJ favorable opinion release for Morgan Stanley.