How to Implement Successful Anti-Corruption FCPA Compliance Programs

Estimated read time 6 min read

Corruption is a vice. It’s an iniquity that should be dealt with using all the available resources. According to FCPA, companies should employ advanced tactics to tackle corruption. Among other things, FCPA—which stands for Foreign Corrupt Practices Act—companies should employ as well as strengthen anti-corruption programs. Even more, legal and compliance personnel—including CFOs—should discuss compliance regulations with their executives. This includes programs that need strengthening. On these lines, here how to roll out a successful anti-corruption program for your company.


FCPA compliance is increasingly becoming a challenge in the modern world. Plus, the geopolitical landscape is becoming challenging day in day out. Consequently, more and more companies have found themselves on the wrong side of the law due to incomplete, faulty, and internal compliance errors. This has led to numerous sanctions against companies. Still worse, these sanctions will keep on hurting coming and affecting companies around the globe—including the United States of America. Even more, most of the world’s fastest-growing economies don’t show mercy when issuing sanctions to non-complying companies. Things like improper payments and frauds can land your company in a hot soup. Are these the things you want to see for your company? Probably, no. Well, then, you have no option than to comply with the regulations. Of course, these regulations keep on changing. But this doesn’t give you an opportunity to do business your way. You can avoid pitfalls that relate to compliance issues. And the only way to beat these hurdles is to master all aspects of compliance—including those touching on anti-corruption programs, you can read this great article for more info.

How to Execute Successful Anti-Corruption Compliance Programs

The first step to compliance is rolling out an effective anti-corruption compliance program. Here are a few things to guide you through this journey.


Compliance starts at the top. Managers must be committed. They must show leadership. Otherwise, that program will fail. As a leader. You must send clear signs that compliance is key and vital when it comes to the success of any business. Even more, the middle management should communicate with the rest of the staff on how integral compliance is to the success of the organization. Remember, if middle-level managers send mixed signals, then the program is likely to fail. So, managers have the biggest role when it comes to compliance. This includes company CEOs, departmental heads, etc. They should clearly show commitment and communicate compliance matters with a lot of clarity.

Adequate Resources

One of the biggest factors that can lead to the failure of the compliance program is the lack of resources. This includes both human and capital resources. Any program must be implemented using enough resources. Otherwise, it will remain to be a song. Remember, you will have to hire compliance managers, assign tasks. Organize workshops, design communication strategies, etc. All these tasks require resources. So, if you want your program to succeed, commit enough sufficient resources towards its implementation.

Compliance Function

Of course, compliance functions and positions are gaining traction in the modern business environment. However, not all companies heed the call to hire these officers. Tasked with overseeing compliance functions, Chief Compliance officers are important components when it comes to dealing with corruption-related vices. Thus, any company needs a complete compliance function desk. This includes individuals, managers, or group leaders. They will collaboratively work together to deliver the compliance dream for your organization.

Engage and Communicate Well

Of course, you may put in place great programs. They may be very exciting. However, if communication lacks, they aren’t going to bear fruits. If the policies and procedures lack clarity, they will be inaccessible. This includes communicating with the employees in a language they clearly understand. In particular, if you can translate these policies into local languages, things will be better. On the other hand, some employees may not understand complex policies—especially those written in jargon. So, be sure to deliver your communication in a simple and clear manner. Establish procedures that have clear guidelines.

Don’t Allow Competing Priorities

How do you compensate for your sales team? Do you base the pay on sales alone? Well, if so, you may be making a mistake. Here is why; your sales team will do anything to hit sales targets at the expense of compliance. This will mess up with your company’s compliance programs. Instead of only using sales to compensate them, integrate compliance benchmarks into their sales targets. This will play a key role when it comes to reinforcing the mutual goals. Even more, you can offer awards to those who show great commitment to compliance.

Business Processes

Having ambition is good. It’s the aim of every business. However, letting your ambition injure your compliance is only going to complicate matters. For instance, if you are expanding into other countries, it’s easier and tempting to ignore internal control. Remember, internal control is an important component when it comes to compliance. So, ensure that you have internal controls. Make sure that they are operating. For more information on SEOs, business processes, and compliance.

Sufficient Monitoring

As a company, it’s important to monitor both employees and third parties. This will help you determine if they are adhering to compliance requirements. Some of the best ways to go about this are linking audit programs and employee interviews. Also, you can conduct financial interviews.

Consistent Enforcement

The law should be applied equally. For instance, if a senior member of your company makes a mistake, be sure to reprimand him/her the same way you do to the juniors. Applying consistent enforcement as well as corrective actions will give compliance an uplift. No one will complain that they are treated unequally. So, deal with ethical violations without favor. Apply corrections equally. Issue suspensions without favor. In a nutshell, nobody should be above the law.

The Bottom-Line

Anti-corruption programs are important for any organization. That’s why CFOs and legal officers should enact and strengthen programs that prevent corrupt practices. For instance, CEOs should pay close attention to FCPA programs. The above guide should help you roll out successful anti-corruption FCPA compliance programs.

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