MyComplianceOffice Blog

According to U.S regulators, one of the most common reasons companies are citied for Foreign Corrupt Practices Act (FCPA) violations is they have beautifully written compliance policies and procedures that are simply not implemented or enforced. Often, the regulators say, management is to blame either through a lack of commitment to a compliance program or sometimes even purposefully trying to circumvent it.  

When it comes to enforcing the Foreign Corrupt Practices Act (FCPA), the U.S. Department of Justice (DOJ) is still trying to figure it out. That’s according to Mike Koehler, professor of Law at Southern Illinois University, who is an FCPA expert.  

The Association of Corporate Counsel (ACC) published an article in May focusing on the top ten things small corporate legal departments need to know about complying with the Foreign Corrupt Practices Act (FCPA). While all ten are good to review, three stand out as critical to making sure your FCPA compliance program is more than just a written policy.  

Telefônica Brasil recently agreed to pay the U.S. Securities & Exchange Commission (SEC) more than $4 million to settle charges brought against the organization for allegedly violating the Foreign Corrupt Practices Act (FCPA). 

Many organizations look to auditors as their primary source of fraud detection. That’s a mistake according to the Association of Certified Fraud Examiners (ACFE). In 2018, an ACFE study found 53 percent of occupational fraud is identified by employees other than auditors. That’s compared  to just 15 percent detected by internal auditors and just 4 percent by external auditors.