Foreign Corrupt Practices Act


The Foreign Corrupt Practices Act (FCPA) is the most widely enforced anti-corruption law, containing both anti-bribery and accounting provisions not only prohibiting corrupt payments to foreign officials, but also prohibiting individuals from knowingly falsifying company records or circumventing internal controls.  

Stinnett’s FCPA/anti-corruption professionals have experience assessing existing compliance programs and aiding organizations in establishing effective anti-corruption programs based on the Ten Hallmarks of an Effective Compliance Program.

We assist clients in monitoring compliance with their anti-corruption programs by utilizing our experience as certified fraud examiners, public accountants, internal auditors and information technology auditors. Our teams leverage technology to review, match and examine vast amounts of data to quickly detect anomalies and trends in the evaluation of compliance with procedures, root cause of exceptions and remediation of related internal control practices.

Engagement examples include:

  • Assist in establishing effective anti-corruption programs
  • Review monitoring procedures for effective program compliance
  • Review internal control activities related to transparent and effective recordkeeping and compliance with accounting provisions
  • Conduct reviews of business development activity for compliance with anti-corruption program guidelines
  • Review third-party representative payment activities for contractual compliance
  • Develop due diligence processes for the evaluation of third party representatives
  • Enhance training and establish guidelines for appropriate participants