Best Practices Under the FCPA and Bribery Act: How to Create a First Class Compliance Program

Over the past few years I have tried to provide the compliance practitioner with solid information that can be used to implement, review and enhance a US Foreign Corrupt Practices Act (FCPA) or UK Bribery Act based compliance program. I am often asked to collect my blog posting regarding what are the current best practices for an anti-corruption/anti-bribery compliance program. In other words, what are the specifics of a compliance program? This volume is an attempt to provide the compliance practitioner with information that can be used for the ‘nuts and bolts’ of compliance. Using a format similar to the recent US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) guide, “A Resource Guide to the U.S. Foreign Corrupt Practices Act. The Foreign Corrupt Practices Act (FCPA)” [the “Guidance”], I have included some of my thoughts on what you can do to create and maintain a best practices compliance program. I have also included some of my prior articles on how to create and maintain such a compliance program using the Six Principles of Adequate Procedures compliance regime under the UK Bribery Act.