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Senior management responsibility for FCPA compliance programs – not the GC?

Guest blogger Jeff Kaplan of Kaplan & Walker LLP writes:

A recently launched benchmarking survey (prepared by Dick Cassin of the FCPA Blog, my partner Rebecca Walker and me) asks respondents to indicate whether the general counsel is the senior official who has been designated to oversee their companies’ anti-corruption compliance program. Thus far more than half have answered no to this question.

Senior management oversight is only one of many anti-corruption compliance program topics covered by the survey. Also included are such challenging areas as board reporting, training third parties, monitoring and compliance incentives, among others.

The survey is still open and information contributed to it is collected anonymously. Participants will receive a complimentary copy of the final report, which hopefully will be of use in addressing this legal risk of growing importance. More information about the survey, and a link to take it, can be found at

(See Jeff’s post of Dec. 7, 2010: FCPA compliance staffing and the inside/outside counsel model; see my post of March 13, 2006: core competencies at Philip Morris include FCPA.).

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