In each podcast, Thomas Fox and Timur Khasanov-Batirov take two typical concepts or probably misconceptions from in-house compliance reality. They check out if these concepts work at emerging jurisdictions.

Corporate Concept #1. We have officially deployed compliance program at a high-risk market. All hallmarks are duly identified in it. I do not understand what kind of priorities I have to consider in addition to regulatory hallmarks.

When enough is enough?

Timur Khasanov-Batirov: Here are my pros:

Argument #1.

To address regulatory expectations you should have a program that is comprised of 10 Hallmarks. Here are your priorities. This is a very straightforward and in my view a very clear philosophy.

Argument #2.

10 Hallmarks cover both legal aspects along with implementation side. If we want to find priorities for particular organization among already identified regulatory priorities we can simply choose them from 10 Hallmarks.

Argument #3.

Attempt to perplex the framework could harm the execution of the program. I do not see any merits from practical side to distract attention of the team and to spare resources on reinventing the wheel.

Thomas Fox:  OK, let me give you some examples, which probably allow you to re-think about priorities. Here are cons:

Argument #1. To read the full story please visit FCPA Compliance Report’s website at:


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