How can a multinational company best safeguard itself and its employees against FCPA prosecutions while doing business in China?

In light of the statute's requirements and complexity, China's business culture, and the prevalence of public corruption in China, in order to best safeguard itself and its employees, prudent multinational corporations should develop strong compliance programs, which should include (1)assessment of the company's business courtesy risks, (2)the establishment of reporting and recording system, (3)designated vendors and pre-approved promotional items, (4)effective compliance organization, and (5)employee training.

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