Viewing Your Anti-Corruption Efforts Through the Lens of the Hallmarks of an Effective Compliance Program

In November 2012, the Criminal Division of the U.S. Department of Justice and the Enforcement Division of the U.S. Securities and Exchange Commission jointly released A Resource Guide to the U.S. Foreign Corrupt Practices Act. The Guide is a clear statement from the government that “this is what we are looking for” in your anti-corruption program. Indeed, when evaluating a compliance program and designing audit procedures to test the efficacy of such programs, it is prudent to consider the elements that the government construes to be of critical importance. This white paper summarizes these program hallmarks and includes excerpts from each section of the Guide and information intended to provide further insight.