This sample checklist illustrates how to implement a necessary element of a comprehensive Foreign Corrupt Practices Act (FCPA) program, and is designed to help compliance professionals, in the United States, ensure they have considered all of the issues. Thorough and well-documented due diligence on third parties is a crucial element in a company’s compliance program to prevent liability under the FCPA.
This sample request form illustrates how to incorporate a necessary element of a comprehensive FCPA program into your company’s compliance library and is designed to help compliance professionals ensure they have considered all of the issues. To avoid violating the FCPA, companies must take care not to give anything of value, including entertainment, to foreign government officials.
This sample filing language illustrates how to incorporate a necessary element of a comprehensive FCPA program into your company’s compliance library and is designed to help compliance professionals ensure they have considered all of the issues. Disclosure language covering FCPA risks must clearly state that the company is aware of corruption risks and has implemented specific compliance efforts.
This sample provision illustrates how to incorporate a necessary element of a comprehensive FCPA program into your company’s compliance library and is designed to help compliance professionals ensure they have considered all of the issues. Certification language for third-party compliance must clearly state parties’ responsibilities in agreeing to not engage in corrupt conduct.
This sample provision illustrates how to incorporate a necessary element of a comprehensive FCPA program into your company’s compliance library and is designed to help compliance professionals ensure they have considered all of the issues. Joint venture conduct policies must clearly state expectations that all partners agree to implement and maintain anti-bribery and anti-corruption controls.
This sample filing illustrates how to implement a necessary element of a comprehensive FCPA program into your company’s compliance library and is designed to help compliance professionals ensure they have considered all of the issues. Disclosure language for SEC filings must clearly state the circumstances surrounding an investigation into alleged violations of the FCPA as well as address cooperation and compliance controls.
This sample provision illustrates how to incorporate a necessary element of a comprehensive FCPA program into your company’s compliance library and is designed to help compliance professionals ensure they have considered all of the issues. Certification language for a policy provision covering facilitating payments must clearly state employees’ responsibilities in dealing with so-called grease payments.
This is a sample anti-corruption policy.