Fcpa Compliance Report

Internal controls are a key tool to operationalize your third party risk management program. Initially, a compliance practitioner should perform an analysis of any third party representative to provide insight into the pattern of dealings with such third parties and, therefore, the areas where additional controls should be considered. The basic internal controls, that should be a part of any financial controls system, include some or all of the following:  A control to correlate the approval of payments made to contracts with third party representatives and your company’s internal system for processing invoices. A control to monitor all situations in which funds can be sent outside the US, in whatever form your company might use, which could include accounts payable computer checks, manual checks, wire transfers, replenishment of petty cash, loans, advances or other forms. A control for the approval of sales discounts to distributors. A control for the approval of accounts receivable write-offs. A control fo