Mar 27, 2015
From the Advisory Institute
ForensicFocus | March 2015
The Critical Path Forward
A robust anti-bribery and corruption program can demonstrate a company’s good faith in regulatory compliance.
As anti-bribery and corruption (ABC) programs mature, and in light of new, tighter Foreign Corrupt Practices Act (FCPA) regulations and the recent focus of government enforcement actions, organizations are looking for ways to improve the effectiveness of their ABC compliance programs.
Companies evaluating their anti-bribery and corruption programs should pay considerable attention to these three components:
- process-level financial controls
- risk assessments at select foreign locations
- third-party intermediary on-boarding procedures
This article includes lessons learned by two companies who faced SEC and Department of Justice inquiries for FCPA violations.