Fcpa Compliance Report

Welcome to Day 4 of 30 Days to a Better Compliance Program. Today we tackle risk assessments. One cannot really say enough about risk assessments in the context of anti-corruption programs. The FCPA Guidance stated it succinctly when it said, “Assessment of risk is fundamental to developing a strong compliance program, and is another factor DOJ and SEC evaluate when assessing a company’s compliance program.” The simple reason is straightforward; one cannot define, plan for, or design an effective compliance program to prevent bribery and corruption unless you can measure the risks you face.  What Should You Assess? What risks should you assess? There are a number of ways you can slice and dice your basic inquiry. The FCPA Guidance states, “Factors to consider, for instance, include risks presented by: the country and industry sector, the business opportunity, potential business partners, level of involvement with governments, amount of government regulation and oversight, and exposure to customs and immigrati