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Playbook

Foreign Corrupt Policies Act (FCPA) Playbook

Your quick-start guide to FCPA: what it requires, common risks, and step-by-step actions to train teams, tighten controls and manage third-party exposure.

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Why this FCPA playbook matters

Get the essentials and the execution steps you can take to stay compliant with FCPA regulations.

Know what the FCPA requires

Body: Clear breakdown of anti-bribery and books & records provisions so you can align policies and controls without guesswork.

Turn guidance into actions

Practical checklists for training, whistleblowing and third-party due diligence that reduce enforcement and reputational risk.

Build resilience across borders

Advice on mapping FCPA to the UK Bribery Act, Sapin II and other global laws to avoid gaps in multinational programs.

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What’s inside this FCPA playbook

You will learn about the Foreign Corrupt Policies Act: 

  • The two pillars; anti-bribery and books and records/internal controls 
  • Practical policy language and approval thresholds 
  • Role-based training scenarios and tracking templates 
  • Third-party due diligence checklists and monitoring triggers 
  • Speak-up and investigations workflows to support defensible remediation
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Why FCPA compliance can’t be ignored

Enforcement actions and penalties under the Foreign Corrupt Practices Act continue to escalate so proactive controls and defensible processes matter.

  • $1.3B

    Largest FCPA settlement to date

    Example of a combined DOJ/SEC settlement in 2020 that illustrates the scale of potential financial exposure.

  • 40+

    Average annual enforcement actions

    Combined DOJ and SEC FCPA investigations and enforcement matters brought each year in recent reporting periods.

  • 90%+

    Cases involve third parties

    Most FCPA enforcement actions trace to intermediaries or third-party partners, highlighting the need for robust supplier and agent due diligence.

Five steps to strengthen FCPA compliance

Use these steps to operationalize the playbook recommendations.

  • Define scope and ownership

    Confirm covered people and activities, assign clear ownership (Legal, Compliance, Procurement) and map existing controls to FCPA obligations.

Define scope and ownership

Confirm covered people and activities, assign clear ownership (Legal, Compliance, Procurement) and map existing controls to FCPA obligations.

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How NAVEX supports your FCPA compliance program

Pair the playbook with the NAVEX One GRC platform to accelerate execution. Features include:  

  • Secure whistleblowing report intake and case management - Anonymous intake, triage workflows and investigation templates to surface and resolve issues quickly 
  • Role-based anti-bribery training - Scenario training and attestations tailored to functions and jurisdictions. 
  • Third-party risk management that scales - Automated screening, risk scoring and ongoing monitoring to reduce intermediary exposure
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Explore more resources on anti-bribery & corruption

Get your FCPA playbook

Turn guidance into action with practical steps for policies, training, third-party diligence and trusted reporting.

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