FCPA Compliance: Documentation Necessary

When under scrutiny for potential Foreign Corrupt Practices Act violations, how does a company prove that it was doing the right thing? The memories of your employees, along with their narratives of what happened will not be persuasive. Sure, interviewing them can uncover helpful information. But nothing is so compelling as documentation that supports the company’s position.

Your company must be able to document several things as it relates to possible FCPA violations:

  1. The existence of a compliance program, and details about what that program actually entails
  2. How the company evaluates employees, vendors, customers, and business partners that may pose FCPA-related risks.
  3. The details surrounding potential violations and actual violations (Receipts, agendas, business operations, background investigations…. all the types of things that show what the company did to ensure compliance and fully investigate any potential sources of problems.)

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