Creating a Foreign Corrupt Practices Act (FCPA) training program
Superior risk and compliance consulting to protect your business
An oilfield services company expanded internationally and was faced with new regulatory requirements and risks. The company wanted to understand the Foreign Corrupt Practices Act, separate fact from fiction, and implement a best-in-class compliance program world-wide. They turned to Aventine Hill Partners for help.
One of our CAE Advisors met with company management to understand their concerns. They had heard stories of other companies receiving advice that resulted in costly over-compliance activities and practices. The Advisor quickly assessed the overall business and control environment along with the corruption perception index for each country the company operated in or had nexus. This resulted in a roadmap for creating an FCPA training program tailored to this company's business. A detailed analysis was performed on key risks areas such as third-party intermediaries, cash-out processes, travel and entertainment, contributions, and gifts.
The resulting FCPA training program covered such items as:
- FCPA current events to provide real world context
- A summary of the law for easier understanding, including federal sentencing guidelines
- Case studies to describe how the law is applied
- High-risk areas and processes applicable to this company
- Best practices for maintaining an effective compliance program
- Tests to assess knowledge.
The Advisor provided onsite training to employees in the U.S. The training was video-recorded for use globally, for new hires, and as an annual refresher. Company management participated in the training helping the Advisor educate employees about situations specific to the company and hypothetical scenarios that may arise.
With help and leadership from Aventine Hill Partners, this company was able to successfully implement and maintain a best-in-class FCPA compliance program tailored to their business and budget. Learn more about our Regulatory Compliance support.