The FCPA requires keeping books, records and accounts in reasonable detail that accurately and fairly reflect the transactions and dispositions of the company.
- The “cardinal rule” of an FCPA–compliant accounting program is documentation of expenditures.
- At a minimum, every marketing expense, facilitating payment, etc… should be documented and cash payments should be discouraged.
- Maintain an internal accounting system assuring that –
- transactions are executed and assets are disposed of only in accordance with management’s authorization
- transactions are recorded to meet GAAP
- periodic audits of existing assets