Best Practices for Reviewing Anti-Corruption Compliance Programs: Implementation, Remediation and Documentation (Part Three of Three)

In an effort to provide concrete, practical advice on the critical but ambiguous task of reviewing anti-corruption compliance programs, the Anti-Corruption Report is publishing a series of three articles on the topic.  This, the third and final article in the series, provides four strategies for conducting the actual review; discusses three steps a company should take post-review; outlines issues surrounding documentation of the review; and examines how FCPA settlement agreements, including monitorships and self-reporting requirements, affect reviews.  The first article in the series discussed the importance of regular anti-corruption compliance reviews; detailed the government’s expectations for reviews; outlined how to create an efficient and effective compliance review schedule; and specified how companies should staff their compliance reviews.  The second installment discussed the chief obstacles companies face when conducting a review; provided strategies for creating management buy-in; described four steps a company should take when preparing for a review; and outlined what risk areas the review should address.

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