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Managing FCPA Audits on a Global Scale

Jaclyn Jaeger | May 22, 2015

Enforcing anti-corruption policies among employees and third parties is one of the foremost concerns for compliance departments, but developing a robust process to assess and uncover bribery risks is no easy task.

At Compliance Week 2015, legal and audit executives with oil services giant Baker Hughes shared how they conduct a robust audit of compliance with Foreign Corrupt Practices Act policies across its global enterprise. This process entails two main types of FCPA audits: internal FCPA audits of high-risk countries and emerging markets where the company has locations, as well as external audits, “which are internal audits conducted by Baker Hughes of external third parties,” explained Marianne Ibrahim, senior counsel of audits and investigations for Baker Hughes.

The overall purpose of these FCPA audits is to identify government points of interaction,...

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