We’ve blogged about Denver, Colorado, telephone and on-site medical translators and interpreters, and certified legal translations by professional legal translators into any foreign language for court filings and for international service of process. If you or your client sells products or services overseas, chances are they are constantly evaluating various scenarios and how they would play out under international corporate compliance (ICC) and, particularly, the Foreign Corrupt Practices Act (FCPA).
Many companies selling products or services overseas utilize an international sales team and require their agents to be familiar with the FCPA, not take actions that will violate its clauses, provide annual certification of compliance, etc. Even with such a system, when doing business overseas situations will arise.
The first step is to always obtain a foreign language translation of all compliance requirements and regulations. Second, whenever a question arises, the US Department of Justice (DOJ) recommends that one should immediately commence a comprehensive internal investigation of the issue and, depending on the findings, decide whether or not a voluntary disclosure should be filed.
In short, the key to compliance is planning. Every company doing business overseas should have:
- A clearly stated company policy (including its professional foreign language translation).
- A senior company officer responsible for Compliance Program oversight and implementation.
- Confidential reporting mechanisms to encourage feedback by company employees of potential Compliance Program violations.
- Monitoring mechanisms for all third-party relationships, including audit rights of their books and records, to assure compliance by overseas employees and foreign sales agents, distributors, consultants, contractors, and joint venture partners (Overseas Partners).
- Disciplinary mechanisms for failure to act in accordance with the Compliance Program.