Insufficient controls governing the expense-reimbursement process can allow employees to bribe foreign officials without detection.  Employees can and have manipulated expense reports in order to provide improper benefits to government officials in the form of gifts, hospitality and charitable contributions and to generate pools of cash from which employees can pay bribes.  This checklist is designed to assist companies in implementing a risk-based expenditures program which can prevent such fraud.  See also “A Guide to Detecting and Preventing Expense-Reimbursement Fraud (Part One of Three)” (Apr. 16, 2014); Part Two; and Part Three.