FCPA Compliance Audits: Lessons From Recent Investigations

Monitoring and Improving the Effectiveness of FCPA Compliance Programs

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

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Conducted on Wednesday, December 17, 2014

Recorded event now available

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Course Materials

This CLE course will provide guidance to counsel and internal audit departments for U.S. companies of all sizes doing business outside the U.S. for planning and executing internal audits that test effective compliance with the Foreign Corrupt Practices Act (FCPA) during a period of increasingly intense enforcement by the DOJ and SEC.


The DOJ and SEC continue to ramp up enforcement of FCPA compliance. Investigations and significant settlements consistently underscore the need for robust and comprehensive compliance. The SEC and DOJ joint guidance on having a risk-specific FCPA compliance program is also instructive.

For example, in July 2014, the SEC announced a settlement with Smith & Wesson over FCPA violations, levying a $1.9 million penalty, noting the extent of Smith & Wesson’s cooperation. The chief of the SEC Enforcement Division’s FCPA Unit stated: “This is a wake-up call for small and medium-size businesses that want to enter into high-risk markets and expand their international sales. When a company makes the strategic decision to sell its products overseas, it must ensure that the right internal controls are in place and operating.”  

Under this intensified spotlight, counsel and Internal Audit Departments of U.S. companies of all sizes involved in international business must monitor and evaluate the effectiveness of FCPA compliance implementation to avoid government investigations and penalties. Thorough and ongoing internal audits are essential to minimize the risks of FCPA violations.

Listen as our authoritative panel reviews the essential components of an effective FCPA audit, identifies troublesome FCPA compliance audit issues, and offers strategies for overcoming audit challenges and executing an effective and cost-efficient audit.



  1. Importance of FCPA audits and risk assessments
    1. Core elements of an anti-corruption compliance program
    2. General parameters of an anti-corruption audit
    3. Risks associated with failure to conduct audit/risk assessment
  2. Forensic examination of anti-corruption compliance
    1. Establishing methodology
    2. Common corruption and fraud schemes
    3. Recommendations for improving financial accounting controls and procedures
  3. Challenges and risks of anti-corruption compliance reviews
    1. Identifying challenges
    2. Strategies for overcoming challenges


Our panel will review these and other key issues:

  • What are the essential components of an effective FCPA audit?
  • What strategies are available to overcome troublesome audit challenges?
  • What can be learned from recent DOJ/SEC investigations and settlements?
  • What steps can counsel take to guide clients and companies in executing cost-efficient audits?


Peter Viksnins
Peter Viksnins
Director in the Forensic Services

Mr. Viksnins has performed forensic accounting investigations and compliance consulting engagements in a number of...  |  Read More

Albert A. Vondra
Albert A. Vondra

Mr. Vondra has extensive financial advisory expertise, including accounting, auditing and business experience covering...  |  Read More

Wilson, David
David A. Wilson

Thompson Hine

Mr. Wilson focuses on complex civil litigation, internal and government investigations, and securities enforcement...  |  Read More

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