White Papers - Risk Solutions

Staying Out of the Headlines: Strategies to Combat Corruption Risk



As anyone who follows news of companies in violation of the U.S. Foreign Corrupt Practices Act (FCPA) will attest, the U.S. Department of Justice and the U.S. Securities and Exchange Commission have engaged in record levels of FCPA investigative and enforcement activities in the past several years. Even companies that have strong codes of conduct forbidding bribery of foreign officials may still find themselves the subject of an FCPA investigation. This white paper (co-authored with Covington & Burling LLP) provides a detailed breakdown of key control weaknesses from 286 cases involving FCPA violations. By identifying whether these control weaknesses or similar ones exist within an organization’s system of internal controls, management can gain a greater understanding on how to develop strategies for preventing or mitigating these risks.