Death Knell for the Compliance Defense?

The bribery allegations against GlaxoSmithKline in its China operations suggest to the writer that it’s time to say “rest in peace” to any notion that on-paper compliance policies can be the basis of an FCPA defense. The stated policies of GSK, notably those that were part of a “Corporate Integrity Agreement” it signed about a year ago as part of record $3 billion settlement over fraud allegations, were exemplary but apparently had no effect.