FCPA Compliance

In order to avoid the consequences of an FCPA violation, it is imperative for companies to enact and maintain detailed compliance policies aimed at the detection and prevention of unethical business practices. Given that there are a wide variety of corruption risks, it is important that a business educate its employees and management about the specific corruption risks relevant to their industry and the countries in which they conduct business. Employees, particularly management-level, should generally be required to undergo updated FCPA compliance training annually. Thorough training on these topics ensures that employees will be able to recognize red flags and understand their reporting responsibilities.

Additionally, a business should conduct an in-depth FCPA risk assessment on an annual basis to ensure strong compliance standards and improve areas of weakness. An effective assessment will include confirmation that internal whistleblowing systems are accessible, as well as ensuring that third-parties are also keeping up with enforcement. In order to maintain an effective compliance program, it is recommended that companies appoint an internal FCPA compliance officer in order to manage the program and ensure its functionality.

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