The "books and records" provisions of the Foreign Corrupt Practices Act:

Question

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The "books and records" provisions of the Foreign Corrupt Practices Act require publicly-held companies to devise and maintain adequate internal controls over payments that constitute bribes. These provisions require companies to keep accurate records of their transactions and to have internal controls in place to prevent and detect violations of anti-bribery laws. The provisions also require companies to maintain accurate books and records that reflect all transactions and to make and keep books, records, and accounts that accurately and fairly reflect the transactions and dispositions of the assets of the company. The provisions do not impose criminal liability on internal or external auditors for failing to detect bribery or corruption in a firm's record-keeping system nor do they require companies to document facilitation payments.

The "Books and Records" Provisions of the Foreign Corrupt Practices