1. FCPA Explained
a. What Companies Are Liable?
b. What Is A “Corrupt Act?”
c. What Constitutes A “Foreign Official?”
d. What Constitutes A “Third-Party Payment?”
e. What Are High-Risk Countries?
2. Developing A FCPA Due Diligence Process
a. Establish A Credible Due Diligence Process
b. Ensure A Valid, Testable Outcome
c. Leverage Proven Methods To Minimize Unforeseen Error or Complication
d. Formally Document The Process
3. Executing The Due Diligence Program
a. Training
b. Risk Assessment
i. Global Footprint
ii. Business Partners And Vendors
c. Third-Party Vetting
d. Document Due Diligence
4. Routine Monitoring Of The Program
a. Risk Assessment
b. Periodic Testing
c. Modifying the Program
5. Voluntary Self-Disclosure
6. FCPA “Red Flags” For Corruption
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