An audit of compliance with Foreign Corrupt Practices Act policies is no easy task. It requires skilled personnel, sophisticated data analytics, and an understanding of the difference between an audit and investigation.

It is also something a compliance program needs to get right. A good FCPA audit can mean the difference between a bribery risk caught and defused early, or one that spirals out of your hands and into those of the Justice Department or Securities and Exchange Commission; just ask Alstom or Avon.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...