Appendix 7 FCPA Acquisition Due Diligence Checklist

• Author: Robert W. Tarun
• Profession: Former Executive Assistant U.S. Attorney in Chicago
• Pages: 917-919

APPENDIX 7

FCPA Acquisition Due

Diligence Checklist

• Corporate Information

• Names and Addresses of Target’s Officers, Directors, Management Level

Employees, Owners and Principal Shareholders (private company)

• Names and Addresses of Target’s Officers, Directors, Management Level

Employees, Owners and Shareholders with Interests of 10% or More (public

company)

• Identification of any Officers, Directors, Management Level Employees,

Owners or Principal Shareholders Who are:

• Current or Former Government Officials or Employees

• Close Family Members of Government Officials or Employees

• FCPA or Anti-Bribery Compliance Policies and Procedures

• Statement of Corporate Compliance Policy

• Internal FCPA or Anti-Bribery Compliance Procedures

• FCPA or Anti-Bribery Compliance Training Materials

• PowerPoint Presentations

• Handouts

• Attendance Lists

• Acknowledgment Forms

• Internal Accounting Control Procedures

• Appropriate Translation of Compliance Policies and Procedures

• International Business Activities

• Countries in which Target has Business Operations

• Countries in which Target makes sales to Government Entities (including

State-Owned Commercial Enterprises)

• Evaluation of Countries against Transparency International Corruption

Perception Index (CPI)

• List of all Registrations, Licenses, Permits and other Government Approvals

held by Target to do business in each Country

• Identification of each Government Agency responsible for administering

Registration, Licensing, Permits and Approvals

• Copies of all Correspondence with Government Agencies relating to

Registration, Licensing, Permits and Approvals

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