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Most people familiar with the Foreign Corrupt Practices Act know of it as an anti-bribery law that imposes stiff penalties for companies that bribe foreign officials. Far fewer focus on the companion provision of the law that requires companies to maintain a system of internal controls that help detect and deter improper payments. Perhaps this oversight happens because, absent a bribe payment or other primary violation, it is unusual for companies to be penalized for failing to implement these internal controls. As a result, many companies don’t identify and consider the effectiveness of operational and financial reporting controls that are relevant to corruption prevention; and in the process fail to benefit from their considerable power in promoting compliance and identifying potential issues early.

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