One interesting point I found is that generally in a longer-term secular bear market, the absolute low of that bear market is generally reached in the middle of the bear market.

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Although the prescription to base your compliance efforts on an assessment of risk is the most basic of common sense axioms, and although it applies generally to your entire compliance program, the Department of Justice has driven the point home and made it clear as well that an anti-corruption risk assessment is an absolute must-do.

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