US Foreign Corrupt Practices Act (FCPA)

Effective compliance program (DOJ/SEC Resource Guide, 2nd ed.) – US Foreign Corrupt Practices Act (FCPA)

US Foreign Corrupt Practices Act (FCPA) P-1: Show commitment from senior management and a clearly articulated anti-corruption policy

DOJ and SEC look for a tone at the top reinforced by middle management, standards communicated unambiguously and followed, and a culture in which business pressure does not override compliance.

Maintained by Gerard BlokdykVerified against the published standard 31 May 2026Control text last updated 21 May 2026

Other controls in Effective compliance program (DOJ/SEC Resource Guide, 2nd ed.) – US Foreign Corrupt Practices Act (FCPA)

P-10 Conduct anti-corruption due diligence in acquisitions and integrate acquired businesses promptly
P-2 Maintain a current code of conduct and risk-based compliance policies and procedures
P-3 Give compliance oversight, autonomy and resources
P-4 Base the program on a corruption risk assessment
P-5 Train and advise directors, employees and, where appropriate, third parties
P-6 Apply incentives and disciplinary measures consistently
P-7 Perform risk-based due diligence on third parties and control payments to them
P-8 Offer confidential reporting and investigate, remediate and learn from misconduct

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MCP endpoint All US Foreign Corrupt Practices Act (FCPA) controls