Starting with the risk, not the policy
A corruption compliance program works when it is built around the company's real exposure: the countries where it operates, the government touchpoints in its business, and the third parties who act for it. Customs brokers, licensing consultants, and sales agents are frequent sources of risk because they deal with officials on the company's behalf. State-owned enterprises count as well, since their employees may be treated as government officials under anti-bribery laws. For companies whose securities trade on US exchanges, the accounting provisions of the Foreign Corrupt Practices Act also require accurate books and adequate internal controls, so vaguely described payments can become a problem even without proof of a bribe.
Where programs tend to fall short
Policies on paper often outpace practice. Gifts and hospitality rules may exist but go unenforced, due diligence on intermediaries may stop after onboarding, and expense approvals may not catch payments with vague descriptions. Training that is not tied to people's actual roles fades quickly. Prosecutors evaluating a company's program have published guidance asking whether it is well designed, adequately resourced, and working in practice, and they look at whether the company tests its own controls. Collect current policies, lists of third parties, diligence files, hotline reports, and audit results to see where the gaps lie.
Building or reviewing the program
We begin with a risk assessment that maps where the company meets government officials and through whom. Policies, approval paths, and monitoring can then be fitted to that map rather than adopted from a template. If a specific concern has already arisen, it should be handled through a privileged review rather than folded into a general program update. Decisions about remediation, discipline, and any disclosure to authorities depend on the facts, current enforcement policy, and the laws of other countries that may apply. The goal is a program people use and the company can explain when asked.
