Question: Devise a program for your company to ensure com- pliance with the Foreign Corrupt Practices Act. What is the importance of corporate culture to any

Devise a program for your company to ensure com- pliance with the Foreign Corrupt Practices Act. What is the importance of corporate culture to any such compli- ance program? See Daniel L. Goelzer, "Designing an FCPA Compliance Program: Minimizing the Risks of Improper Foreign Payments," 18 Northwestern Journal of International Law & Business 282 (1998). See also Patrick J. Head, "The Development of Compliance Programs: One Company's Experience," 18 Northwestern Journal of International Law & Business 535 (1998).

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