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Anti-Corruption and Anti-Bribery

Foreign Corrupt Practices Act (FCPA)

The Anti-Corruption and Anti-Bribery Library currently includes the Foreign Corrupt Practices Act (FCPA) Playbook. It is a fully loaded and editable template that represents the core of what is generally required to demonstrate compliance with the U.S. Department of Justice Criminal Division’s evaluation criteria for an effective corporate compliance program.

The Foreign Corrupt Practices Act (FCPA) Playbook addresses the following areas:

  • Adopt a Formal Written Compliance Policy
  • Cultivate a Culture of Compliance Among Employees
  • Conduct Regular Audits of the Compliance Program
  • Develop a Risk-based Assessment for each Jurisdiction
  • Evaluate Key Areas of Risk
  • Engage Local Counsel when Doing Business Abroad
  • Effectively Train Employees in FCPA Compliance
  • Designate Anti-corruption Personnel
  • Develop Reporting Mechanisms
  • Review All Intermediaries
  • Keep Accurate Books and Records
  • Document key FCPA Compliance Measures
  • Maintain Compliant Meal and Entertainment Expenditure
  • Maintain Compliant Gift Expenditure
  • Maintain Compliant Travel Expenditure

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