Most compliance practitioners are aware the Foreign Corrupt Practices Act has both an anti-bribery component, enforced by the Justice Department, and accounting provisions component, enforced by the Securities and Exchange Commissioner. The accounting provisions include both books and records and internal controls. The books and records component requires a company (issuer in the language of the statute) to “make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the issuer.”
