According to papers filed by the government in an FCPA prosecution late last year, the defendant company (RAE Systems) had learned of a practice of bribery in its joint venture in China but also concluded that “implementing an effective compliance program could hurt sales.” Company personnel did, however, want to “evidence” that they were trying to stop bribery and so they provided “some FCPA training” to at-risk personnel. In this attention-getting case, the Justice Department seemed to suggest – somewhat ominously – that the training (which it labeled a “half measure”) may have enabled the criminality to continue (by creating a possible defense in the event the bribery was detected).
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