DFDL Thailand Tax Director and Head of Regional Compliance & Investigations Jonathan Blaine’s article “DOJ Updates Guidance on Evaluation of FCPA Compliance Programs” was recently featured in Volume 2 of Thai-American Business Magazine this year. In this article he outlines the challenges faced by corporations in designing and implementing effective anti-corruption compliance programs, especially those operating in ‘high risk’ jurisdictions as can be found in South-East Asia. Jonathan describes how such companies often seek guidance from US and UK legislation such as the Foreign Corrupt Practices Act (“FCPA”) and the UK Bribery Act 2010 (“UKBA”) in formulating their compliance programs, while noting the recent passing of anti-corruption and anti-bribery legislation by a number of ASEAN states. The article also mentions updated guidance in relation to the FCPA issued by the Department of Justice in April 2019 that better assists US companies in setting their compliance programs and ensuring their proper implementation. This will be of particular importance for companies operating in ASEAN states especially as they become subject to anti-corruption or anti-bribery laws soon to take effect in certain jurisdictions.
Thailand Tax Director & Head of Regional Compliance & Investigations