Enacted in 1977, the FCPA has rarely been enforced. The change began in 2004, though the reasons are

Enacted in 1977, the FCPA has rarely been enforced. The change began in 2004, though the reasons are not entirely clear as to why there has been such an increase in enforcement. Figure discount plane tickets 1 (right) tracks the number of corporate and individual enforcement actions since 2002.
The recent enforcement action against Morgan Stanley's managing director Garth Peterson demonstrated the benefits of having discount plane tickets a minimum best practices discount plane tickets compliance programme in place. Both the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) went out of their way to praise the Morgan Stanley Compliance Programme. This written praise demonstrated that not only do companies receive credit from the DOJ for having a compliance programme in place, but also provided solid information as to why the DOJ declined to prosecute discount plane tickets Morgan Stanley.
A Company should develop and promulgate a clearly articulated and visible corporate policy against violations of the FCPA, including its books and records, and internal discount plane tickets controls provisions in a written compliance code.
The Company will ensure that its senior management provides strong, explicit, and visible support and commitment to its corporate policy discount plane tickets against violations of the anti-corruption laws and its compliance code.
A Company should develop compliance procedures designed to reduce the prospect of violations. These anti-corruption standards and procedures shall apply to all directors, officers, employees discount plane tickets and outside parties acting on behalf of the company, including agents, intermediaries and other business discount plane tickets partners. Such standards shall include policies governing:
A Company should review its anti-corruption compliance discount plane tickets procedures, no less than annually, and update them as appropriate, taking into account discount plane tickets relevant developments discount plane tickets in the field and evolving standards, and update them as necessary to ensure their continued effectiveness.
Responsibility should be assigned to senior corporate executives of the Company for the implementation and oversight of their anti-corruption policies. Each should report directly to their legal director as well as the Company's board of directors whom shall have an adequate level of autonomy from management, sufficient resources and authority to maintain such autonomy.
A Company should have a system of financial and accounting procedures, including a system of internal controls designed to warrant the maintenance of fair and accurate books, records, and accounts to guarantee they cannot be used for the purpose of foreign bribery or concealing such bribery.
A Company should implement mechanisms designed to ensure that its anti-corruption discount plane tickets policies are communicated effectively to all directors, officers, employees, agents and business partners. It should include periodic training and annual certifications of compliance with the requirements needed.
- internal and confidential reporting and protection of those reporting breaches of the law concerning anti-corruption occurring within the company, suspected criminal conduct, and/or violations of the compliance; discount plane tickets and
A Company should have appropriate disciplinary procedures to address violations of the Company's compliance code. This should include procedures discount plane tickets to ensure that where misconduct is discovered, reasonable steps are taken to remedy the harm resulting from such misconduct, discount plane tickets and to ensure that steps are taken to prevent further misconduct occurring, making modifications necessary to ensure programme effectiveness.
To the extent that the use of agents and business partners is permitted at all by the Company, they should institute appropriate due diligence and compliance requirements pertaining to the retention and oversight of all agents and business partners, including:
A Company should include standard discount plane tickets provisions in contracts with all agents and business partners that are reasonably calculated discount plane tickets to prevent violations of the anti-corruption laws, which should include:
A Company should conduct periodic reviews and testing discount plane tickets of its anti-corruption compliance code designed to evaluate and improve their effectiveness in preventing and detecting violations of anti-corruption laws and the Company's discount plane tickets anti-corruption code, taking into account relevant developments in the field and evolving international and industry standards.
The US DOJ has provided specific information on what constitutes the minimum 'best practices' compliance programme. The benefits are now readily available and clear to prevent and detect violations of the FCPA, but also to protect discount plane tickets a company from any enforcement discount plane tickets action. These measures discount plane tickets have been put in place to make sure corruption in the work place is left in the past. n