The role of global payroll in FCPA compliance is not often considered in operationalizing your compliance program, yet the monies to fund bribes in violation of the FCPA must come from somewhere. Unfortunately, one of those places is out of payroll. All Chief Compliance Officers need to sit down with his or her head of payroll, have them explain the role of payroll, then you should to review the internal controls in place to see how they facilitate the goals of compliance. From that review you can then determine how to use payroll to See more +

The role of global payroll in FCPA compliance is not often considered in operationalizing your compliance program, yet the monies to fund bribes in violation of the FCPA must come from somewhere. Unfortunately, one of those places is out of payroll. All Chief Compliance Officers need to sit down with his or her head of payroll, have them explain the role of payroll, then you should to review the internal controls in place to see how they facilitate the goals of compliance. From that review you can then determine how to use payroll to help to operationalize your compliance program. See less -