FCPA Books and Records Compliance

Meeting FCPA Accounting Requirements and Minimizing Liability Risks

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Thursday, February 28, 2013

Recorded event now available

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Course Materials

This CLE course will prepare counsel for companies doing business internationally to comply with the books and records provisions of the Foreign Corrupt Practices Act (FCPA) and minimize the risks of FCPA violations.


The FCPA’s accounting provisions include recordkeeping and internal control requirements that obligate companies subject to SEC jurisdiction (SEC Issuers) to have policies and procedures that ensure appropriate authorization and recording of all transactions to maintain accurate and detailed books and records. disposition of company assets.

The FCPA accounting provisions are designed to promote transparency and to prevent and detect FCPA violations. However, complying with these accounting provisions can be a challenge in countries where government interactions, recordkeeping and internal controls practices differ significantly from U.S. practices.

Failure to comply with these FCPA provisions can result in significant fines and penalties. Therefore, it is critical for SEC Issuers and their counsel to have an effective compliance program in place to reduce the risk of violations. The subject is also important to any companies that may in the future become subject to SEC jurisdiction or that do business with SEC Issuers.

Listen as our authoritative panel examines the FCPA books and records and internal controls requirements, identifies FCPA risks, and offers best practices for complying with those requirements.



  1. FCPA accounting provisions
    1. Statutory requirements
    2. SEC enforcement authority
  2. SEC Guidance on the accounting provisions
    1. DOJ/SEC guidance
    2. Representative enforcement actions
    3. Particular challenges
  3. Complying with books and records requirements
    1. Key elements of FCPA compliance program
    2. Internal audit and forensic reviews
    3. Training
    4. Review and remediation of internal controls


The panel will review these and other key questions:

  • What records are companies mandated to maintain under the FCPA books and records requirement?
  • What strategies can counsel utilize to ensure compliance with the FCPA books and records provisions?
  • What does the recently issued DOJ and SEC resource guide offer businesses to assist with compliance?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Edward J. Fishman
Edward J. Fishman

K&L Gates

Mr. Fishman advises clients with respect to government and internal corporate investigations, corporate transactions,...  |  Read More

Luke T. Cadigan
Luke T. Cadigan

K&L Gates

He concentrates his practice on securities enforcement matters, internal investigations, regulatory compliance, and...  |  Read More

Manny A. Alas
Manny A. Alas
Advisory Forensic Services Partner

He leads the New York Forensic Services Practice group and is the co-leader of the firm's FCPA practice. His FCPA...  |  Read More

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