This article provides practical guidance on the most frequently asked questions by legal and compliance personnel at late-stage private and newly public tech and fintech companies around anti-corruption compliance training.

1. When do I need to start training personnel?

A common misconception among legal and compliance personnel is that there is no need to worry about anti-corruption compliance training until after the company has reached a certain size or valuation or after it has gone through an IPO. While it may be true as a practical matter that a company is less likely to attract regulatory scrutiny if it is a relatively small private company, a tech or fintech company organized under the laws of the U.S. or that has its principal place of business in the U.S. (as well as its officers, directors, employees, agents or shareholders acting on its behalf) are subject to the “anti-bribery provisions” of the Foreign Corrupt Practices Act (FCPA), as enforced by the U.S. Department of Justice.