FCPA Compliance Program Checklist

• Author: David A. Steiger
• Pages: 473-475

Appendix I

FCPA Compliance

Program Checklist

473

1. Goals

• Prevention and detection

• Demonstration of commitment to legal business practices

2. Risk Assessment of Foreign Operations

• High-risk countries

• Interaction with foreign governmental ofcials

• Foreign governmental approvals or regulation

• Business dealings with foreign governments

• Business partners

• Foreign tax issues

• Customs and import/export

• Third-party consultants, agents, and advisors

• sales agents

• customs brokers

• government relations consultants

• tax advisors

• customers

• consultants assisting with permitting or licensing

• outside lawyers interacting with government ofcials

• Foreign acquisitions and joint ventures

• Existing compliance functions

• Past instances of noncompliance

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