Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program

This report from leading compliance expert Thomas Fox lays out what you need to consider in your anti-corruption and anti-bribery compliance programme. The author draws on his own experience and on the views of both FCPA practitioners and commentators from other areas of business study and review.

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  • Publication date: August, 2014
  • Pages: 149
  • ISBN: 9781783581597


If you cannot demonstrate effective compliance, your organisation is at risk.
This brand new report from Compliance Week and Ark Group explains exactly what you need to consider in your anti-corruption and anti-bribery compliance programme. While there are other books on anti-corruption and anti-bribery enforcement, none deal as clearly with the “how” of doing business in an increasingly regulated market.

Written by leading compliance expert Thomas Fox, this report draws on his experience, as well as on the views of both FCPA practitioners and commentators from other areas of business. This is your complete step-by step guide on “doing compliance”.

It offers you practical advice on building a framework for an effective anti-corruption compliance programme, including:

  • Implementing clearly articulated anti-corruption compliance policies and procedures;
  • Crafting a comprehensive code of conduct that applies to all employees worldwide – with information on what should be in the written basics of your compliance programme and how best to implement these controls;
  • Carrying out effective risk assessments and due diligence checks;
  • Monitoring and updating your compliance program;
  • Managing compliance during mergers and acquisitions – making sure you don’t ''buy in’' a compliance violation;
  • Understanding facilitation payments, the differences between the UK Bribery Act and the FCPA, and what constitutes a bribe.

These days, enforcement is tougher than ever before and all  companies need to have an effective program in place. Doing Compliance is your guide to achieve this.


Chapter 1: Where it all begins – Commitment from senior management and a clearly articulated policy against corruption

Chapter 2: Some written controls

Chapter 3: For the CCO – Oversight, autonomy, and resources

Chapter 4: The cornerstone of your compliance program – Risk assessments

Chapter 5: Getting out on the road – Training and continuous advice

Chapter 6: Do as I do and as I say – Hiring, incentive, and disciplinary measures

Chapter 7: Your greatest source of FCPA risk

Chapter 8: How do I love thee – Confidential reporting and internal investigations

Chapter 9: How to get better

Chapter 10: Should I or shouldn’t I? Mergers and acquisitions

Chapter 11: A few words about facilitation payments

Check our Executive Summary and full table of contents here


Thomas Fox
Thomas Fox has practiced law for over 30 years. He has been a trial lawyer in private practice, a general counsel in the corporate world, and is now recognized as one the leading experts on the Foreign Corrupt Practices Act (FCPA) and compliance programs relating to both the FCPA and other anti-corruption laws. He is the author of two prior award-winning books on the FCPA: Lessons Learning on Compliance and Ethics and Best Practices Under the FCPA and UK Bribery Act. He blogs daily on all things FCPA on his award winning blogsite, The FCPA Compliance and Ethics Blog, and podcasts on all things anti-corruption on The FCPA Compliance and Ethics Report. Fox writes for a variety of anti-corruption compliance magazines and publications, and is a featured columnist for Compliance Week. He can be reached via his email address.

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