We are occasionally asked what impact, if any, the FCPA has on internal controls other than asking the obvious question, “Have you seen any violations of the FCPA?” Many people might not be aware that the FCPA calls out specific internal control responsibilities as part of their Books and Records and Internal Control provisions, which require:

When considering the acquisition of a Foreign entity, it is prudent to review their internal controls for any issues that could be cited under the Foreign Corrupt Practices Act (FCPA). Large fines and increasing enforcement are causing companies to think twice before jumping in to new deals.