Should you get an FCPA compliance certificate from Iraq/Afghanistan Contractors?

FROM A
DIFFERENT ANGLE by Kenneth Rijock

Financial Crime Consultant, for World-Check

8 February 2010

A US contractor formerly involved in Iraq pled guilty this week to smuggling in more than $800,000 from the Middle East. Bulk cash smuggling issues aside, the explosion of cases involving American contractors in Iraq who are charged with criminal conduct is disturbing. Many of these cases involve corruption; therefore, as a banker handling these individuals as customers, should you not protect yourself?

I propose that you obtain, from all of your clients who have ever been involved in contract work for the US government in the Middle East region, a certificate that attests to their knowledge of, and in full compliance with, the Foreign Corrupt Practice Act. It should affirm that the client's FCPA programme has:

A written FCPA compliance manual.
A comprehensive training programme.
A regular external audit of the programme.
An FCPA compliance officer responsible to the board of directors.
Oversight and supervision of the programme by the board.

To do otherwise may invite adverse publicity, and possibly even reputation damage, when the client's FCPA transgressions result in an indictment*.

_______________________________________________________________________________________________________

* Let me recommend to you Michael Osajda's outstanding white paper, " The FCPA and Why it Matters." It can be found at: http://www.world-check.com/whitepapers/2010/

The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.

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