Anti-Bribery / Anti-Corruption Policy (FCPA / UKBA) review

Anti-bribery policy under FCPA + UK Bribery Act + multi-jurisdiction baselines.

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6 document-specific checks
+ 104 general checks
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What it checks

FCPA anti-bribery prohibition

Policy must prohibit corrupt payments to foreign officials (Exchange Act § 30A, 15 U.S.C. § 78dd-1; FCPA §§ 104, 104A, 15 U.S.C. §§ 78dd-2, 78dd-3).

Critical · POL-006

Third-party / agent / intermediary due diligence

Policy must require due diligence on third parties / agents / intermediaries.

Critical · POL-007

Books-and-records + internal-controls (FCPA accounting)

Policy must address FCPA accounting provisions — accurate books and records + adequate internal controls.

Critical · POL-008

Facilitating payments — narrowness / prohibition recital

Policy must address facilitating payments (typically prohibited despite the narrow FCPA exception).

Warning · POL-009

UK Bribery Act / cross-border applicability

Policy should address UK Bribery Act 2010 + other non-US anti-corruption regimes.

Warning · POL-010

Gifts, hospitality, charitable contributions thresholds

Policy must address gifts / hospitality / charitable contributions / political contributions (US + non-US).

Critical · POL-011

Every run also applies 104 general checks that belong to any agreement: structure, parties and signatures, defined terms, cross-references, dates, amounts, and one-sided terms.

Often reviewed with

Code of Conduct / Ethics

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