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April 14, 2017

Asialaw: Insights into Anti-Corruption and Compliance Programs from Tilleke & Gibbins


Anti-corruption continues to be an important area of focus under the current Thai government and an area of concern for companies striving to comply with the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, according to an article published by Asialaw. The article, written by Karry Lai, includes interviews with John Frangos and Michael Ramirez of Tilleke & Gibbins.

The government amended the Organic Act on Anti-Corruption in 2015 to include new offenses for bribery and stricter penalties for government officials. “Corporate criminal liability was introduced in the Act where associated persons in a bribe could expose companies to being guilty of a corrupt act,” said John. “However, if a company implements proper internal measures, the liability would be limited.”

Focusing on those internal measures, companies need to set up robust internal compliance programs. “These plans are especially important for companies with procurement contracts that could involve potential wrongdoings with vendors and middlemen that could include wrongful behaviour, fraud, and misappropriation,” according to Michael. “One of the weakest areas for companies when setting up internal compliance programs is to prepare a program that is localized. Some companies may be new to Thailand and have no idea how to ensure employees understand the program and make sure systems apply to the reality of doing business, not just a broad, one-size-fits-all program.”

To read the full article about the latest trends in anti-corruption enforcement in Thailand, please visit the Asialaw website.