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Driving effective FCPA compliance with advanced management controls and ISO 37001

Finding the holy grail.

Within the current regulatory landscape, multinational companies can expect continued, if not intensifying, scrutiny of transactions and relationships by authorities seeking to thwart official bribery and level the commercial playing field. Strengthening basic FCPA controls and accelerating the use of automated monitoring tools and continuing efforts to prevent improper payments can help companies enhance their financial well-being, business reputation, and potential for growth and success—and show authorities and stakeholders that they are committed to doing business the right way.

Starting with the basics

Companies have at their ready disposal the recent 2016 guidance of the International Organization for Standardization (ISO) to guide them in the journey to implementation of advanced management controls. The recently published guidance contained in ISO 37001 (“Anti-Bribery management systems—Requirements with guidance for use) contains an essential list of anti-bribery controls that are “applicable to small, medium, and large organizations in all sectors” and recommends, among other things, the following foundational financial controls1:

1.         Effective segregation of duties

2.         Defined delegations of authority

3.         Validation of required approvals

4.         Countersignature requirements for payment approvals

5.         Submission of supporting documentation

6.         Stringent controls on cash

7.         Detailed requirements for transaction descriptions

8.         Management review of significant transactions

9.         Independent financial audits and transaction testing

FCPA compliance tools for a global marketplace

Multinational companies can expect continued, if not intensifying, scrutiny of transactions and relationships by authorities seeking to thwart official bribery and level the commercial playing field. Opportunists, meanwhile, will continue stepping over the line, illicitly currying favor with authorities to secure prized business. Strengthening basic FCPA controls and accelerating the use of automated monitoring tools and continuing efforts to prevent improper payments can help companies enhance their financial well-being, business reputation, and potential for growth and success—and show authorities and stakeholders that they are committed to doing business the right way.

1 Anti-bribery management systems, http://www.iso.org/iso/iso37001.

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