One of the themes coming out of the talks given by representatives of the Department of Justice and Securities and Exchange Commission at FCPA compliance conferences is that of documentation. While many companies focus on the specifics of a best practices FCPA compliance program, we believe that companies should also make documentation an over-arching principal in their compliance programs. By this we mean that everything done or performed within the context of your FCPA compliance program should be documented so that if your company is investigated, it can quickly and efficiently provide documentation of its work. Not much will give you more credibility with a prosecutor than responding quickly with documentation of your compliance program.