In response to the aggressive enforcement environment, companies have been revising policies for travel, gifts, entertainment, and hospitality. As they do so, it is important for each company to consider these questions –

What is the precise risk which is being addressed?

How will the policy minimize the risk of bribery?

How will internal accounting controls incorporate these policies?

Companies know that the risks of misconduct and misuse of money is significant. Many bribery schemes have developed under the accounting control radar screen when actors took excessive amounts of money from petty cash, or used other accounts to funnel illegal bribes to government customers. For this reason, the design of policies is a fundamental piece of any compliance program.

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