Course Overview
Course Content
Module 1: The Global Impact of Corruption
- Real-world consequences of bribery and corruption
- Economic and social costs to developing nations
- Why anti-corruption efforts matter beyond compliance
- Hidden incentives that drive corrupt behavior
Module 2: Legal Framework and Enforcement
- History and purpose of the Foreign Corrupt Practices Act (FCPA)
- UK Bribery Act and international anti-corruption initiatives
- Department of Justice (DOJ) and SEC enforcement actions
- Criminal and civil penalties for violations
- Recent high-profile cases and settlement amounts
Module 3: Understanding “Something of Value”
- Cash payments and monetary bribes
- Gifts and their permissible limits
- Meals, entertainment, and hospitality
- Travel expenses and sponsored trips
- Employment opportunities for relatives
- Charitable donations and political contributions
- Stock tips, trade secrets, and other intangible benefits
- Applying the “legitimate business purpose” test
Module 4: Who Is a “Public Official”?
- Broad FCPA definition beyond government employees
- State-owned enterprise employees
- Officials of public international organizations
- Political party officials and candidates
- Royal family members and their representatives
- Employees of government-controlled entities
Module 5: Third-Party Liability
- “Knowing” standard under the FCPA
- Risks posed by agents, distributors, and consultants
- Red flags in third-party relationships
- Due diligence requirements
- Contractual protections and monitoring obligations
Module 6: Facilitation Payments
- What qualifies as a facilitation or “grease” payment
- Legal status under FCPA vs. UK Bribery Act
- Documentation and reporting requirements
- Company policies that go beyond legal minimums
- Practical alternatives to facilitation payments
Module 7: Practical Application
- Scenario-based decision making
- Identifying red flags in business situations
- Escalation procedures and reporting channels
- Books and records requirements
- Internal controls and compliance programs
Who This Course Is For

Certificate & Compliance
Upon successful completion, learners receive an official certificate of completion demonstrating compliance with DOJ and SEC expectations for FCPA training programs.
The course includes scenario-based assessments that test judgment and decision-making skills, not just factual recall. This ensures employees can apply anti-corruption principles in the ambiguous situations they’re likely to encounter.
Regulatory Alignment:
- Meets DOJ guidelines for effective compliance programs
- Aligns with SEC expectations for anti-corruption training
- Supports UK Bribery Act compliance for international operations
- Provides documentation for corporate governance requirements
- Demonstrates reasonable precautions and good faith compliance efforts
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Don’t Let a Preventable Violation Cost You Millions
FCPA enforcement actions have resulted in settlements exceeding $2.5 billion in recent years. The most effective defense is a well-trained workforce that recognizes and avoids corrupt practices before they become violations.
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