FCPA Compliance: Meeting FCPA Requirements and Minimizing Liability Risks

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

Conducted on Wednesday, September 18, 2019

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE course will provide guidance on Foreign Corrupt Practices Act (FCPA) compliance, including the requirements related to gifts and hospitality, as well as books and records. The panel will also discuss identifying government officials and third-party due diligence. The panel will offer best practices for compliance.


Any company conducting business internationally needs to be aware of the compliance risks under the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. Challenges abound. The handling of gifts and hospitality to and from government representatives requires a determination of whether a gift is a lawful expression consistent with a country’s culture or one that constitutes bribery. Gifts, travel, and entertainment are high risk areas for which companies need to implement safeguards to ensure compliance.

Risks also arise in relationships with agents and other third parties. Conducting thorough third-party due diligence can mean the difference between value added to the company and problems that lead to an investigation.

The FCPA also includes accounting, recordkeeping, and internal control requirements that obligate companies subject to SEC jurisdiction to have policies and procedures that ensure appropriate authorization and recording of all transactions to maintain accurate and detailed books and records. Failure to comply can result in significant fines and penalties.

Listen as our authoritative panel of experienced practitioners examines the requirements of the FCPA and other anti-bribery laws, and provides insights into the compliance challenges associated with gifts and hospitality, third party due diligence, and maintaining appropriate internal controls. The panel will also discuss recent enforcement action in the context of offering best practices for compliance.



  1. Overview of FCPA
  2. Regional business culture/practice risks
  3. Identifying foreign officials
  4. Gifts, entertainment, and hospitality
  5. Third-party due diligence
  6. Books and records compliance
  7. Monitoring
  8. Training of third parties/vendors
  9. Recent enforcement
  10. Developing culture of compliance
  11. Steps to take if misconduct is suspected or discovered


The panel will review these and other key issues:

  • When do gifts to foreign officials cross the line from respecting local customs and culture to being viewed as bribery?
  • What unique FCPA risks are created by different types of third parties?
  • What records are companies mandated to maintain under the FCPA books and records requirement?
  • What steps should companies and counsel take when misconduct is suspected or discovered?


Fetzer, Lindsey
Lindsey B. Fetzer

Bass Berry & Sims

Ms. Fetzer focuses her practice on white collar and corporate compliance matters, including healthcare fraud and abuse...  |  Read More

Thaddeus R. McBride

Bass Berry & Sims

Mr. McBride represents companies and individuals in international trade regulatory, compliance, investigative, and...  |  Read More

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