Resource Author: Department of Justice (US)


This resource is used by prosecutors at the United States Department of Justice to assist their evaluation of the effectiveness of a corporation’s compliance program. The sample topics and questions contained in the resource may also assist businesses to self-assess their own compliance programs and ensure their programs are well-designed, adequately resourced, empowered to function effectively and work in practice.

This comprehensive guidance document provides a detailed analysis of the United States Foreign Corrupt Practices Act (FCPA) and its enforcement. Topics include who and what is covered by the FCPA, the jurisdictional reach of the FCPA, relevant definitions and features of effective compliance programs. The guidance also contains hypotheticals, examples of enforcement actions and summaries of applicable case law.

The United States (US) Department of Justice has an extensive track record of enforcing foreign bribery matters, including against companies that are not registered in the US. This site shows the Department of Justice's foreign bribery enforcement track record.

United States (US) authorities investigate and prosecute foreign bribery that takes place outside of the US, including where US citizens are involved, where payments are in US dollars and where companies are 'issuers' in US capital markets. This policy sets out the US Department of Justice's policy for giving significant discounts in penalty and circumstances in which authorities may not prosecute.