Anti-corruption auditing has become commonplace in the past few years, but as a general matter the audit process tends to occur too infrequently to serve as a company’s only form compliance “checking.”
For this reason, monitoring – meaning real-time checking – can be an important step to ensuring anti-corruption compliance, particularly when it is required of an organization’s business personnel who generally have the ability to act more in real time than do members of a compliance function.
Companies on the fence about whether to mandate monitoring – and compliance officers seeking support for doing so – may be interested to know that more than half of the respondents to date in our benchmarking survey reported that they do have formal standards for monitoring compliance by third-party intermediaries (such as requirements that on an ongoing basis business personnel review such intermediaries’ invoices to see if they suggest violations of anti-corruption laws). More detailed findings and analysis of this issue (based upon the entire survey population) will be included in the benchmarking report to be published once the survey has closed.
Have you taken the Anti-Corruption Compliance Program Benchmarking Survey yet? Participating companies contribute information anonymously and will receive a complimentary copy of the final report, with findings and analyses not only regarding monitoring but a host of other important compliance practices.
The survey is a joint effort of Kaplan & Walker LLP and the FCPA Blog.
To learn more about it, please click here.
Jeffrey M. Kaplan, a partner at Kaplan & Walker LLP, has practiced in the compliance program area since 1991. He can be reached at [email protected].
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