In our last article we discussed the speech by Assistant Attorney General, for the Criminal Division of the US Department of Justice (DOJ), Lanny Breuer at the Compliance Week 2010 Annual Conference where he outlined what he believed are elements of an effective FCPA compliance program. One of the sources Breuer cited as a benchmark is the Organization for Economic Co-operation and Development OECD Good Practice Guidance on Internal Controls, Ethics, and Compliance. This article will discuss the OECD elements of an effective compliance program.