FCPA Lessons Learned: Failures in Internal Controls

In a recent white paper, entitled, “Staying out of the Headlines: Strategies to Combat Corruption Risk” jointly produced by the consulting firm of Protiviti and the law firm of Covington and Burling, the authors reviewed 286 FCPA cases and analyzed the internal control weaknesses which led to FCPA enforcement actions. From this review, the authors derived a Top Five of Control Weaknesses. This article will review these findings and the authors’ guidance on how a company might use this information to assist it to enhance its FCPA compliance program.