Most Foreign Corrupt Practices Act (FCPA) practitioners understand the requirement for a compliance policy under the FCPA. However many practitioners, particularly lawyers practicing in the compliance field, do not understand the requirement for proper Internal Controls. Generally speaking, Internal Controls are policies, procedures and training which are installed to safeguard that a business’ assets are utilized in an appropriate manner; with proper oversight and approval and that all company transactions are properly recorded in its books and records.
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