Foreign Corrupt Practices Act (FCPA) Workbook (May 2015)
Review of contracts with supply chain vendors to confirm that the appropriate FCPA compliance terms and conditions are in place.
Determine that actual due diligence took place on the third party vendor.
Review FCPA compliance training program; both the substance of the program and attendance records.
Does the third party vendor have a hotline or any other reporting mechanism for allegations of compliance violations? If so how are such reports maintained. Review any reports of compliance violations or issues that arose through anonymous, hotline or any other reporting mechanism.
For additional audit procedures, a red flag checklist and 3rd party contractor checklist login and download the template.