Foreign Corrupt Practices Act Compliance Programs Checklist

Summary

This checklist identifies the main considerations for management and boards of companies with international dealings, or multinational companies seeking to develop policies and procedures pertaining to compliance with the U.S. Foreign Corrupt Practices Act ("FCPA"). The checklist provides recommendations surrounding the formulation of a company's code of ethics, training modules, risk assessment tools, as well as oversight and monitoring programs. Finally, the checklist also addresses issues surrounding the creation of a company culture, and discusses enforcement and self-disclosure options to promote further compliance with the FCPA.