Recent enforcement activities in Canada under its Corruption of Foreign Public Officials Act (CFPOA), including the conviction of Niko Resources Ltd. (Niko) in June of last year and ongoing high-profile Royal Canadian Mounted Police (RCMP) investigations of other Canadian companies, has caught the attention of boards and executives across the country. Additional prosecutions or settlements are expected in the near future, as it is understood that the RCMP has over 30 foreign corruption investigations ongoing at this time.

This note highlights the importance of conducting a thorough risk assessment before designing and implementing compliance processes and procedures.