Anti-Bribery and Corruption

Foreign Corrupt Practices Act (FCPA)

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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