Checklist for Complying with the Foreign Corrupt Practices Act

摘要

Because there are not many sources of guidance regarding compliance with the Foreign Corrupt Practices Act (FCPA), the resulting uncertainty has led to different interpretations about what constitutes an appropriate compliance program. It is certain, however, that some form of compliance program is necessary for all companies operating transnationally, and such a program should be logically structured to take into account the legal aspects of the FCPA, as well as the business operations and history of the company.