Lessons Learned by Motorola Solutions, ExxonMobil and VMWare on the Role of Risk in Designing and Implementing an FCPA Compliance Program

Risk assessment procedures are the foundation of an effective and efficient anti-corruption compliance program.  At the recent Momentum Anti-Corruption Global Congress, three experienced in-house compliance counsel – currently at Motorola Solutions, ExxonMobil and VMWare – shared their insight and experience creating and implementing risk-based anti-corruption compliance programs.  Specifically, the panelists, speaking in their individual capacities, described the corruption risks raised by their suppliers, customers and partners; offered differing takes on the role of certification and risk coding; shared best practices born of experience for interacting with employees and third parties; relayed their experiences with third-party sponsorship; and emphasized the central place of mitigation in any risk-based compliance program.  Jay Musoff, a partner at Loeb & Loeb LLP, moderated the panel.

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