Investigators must be familiar with the OECD Anti-Bribery Convention, which was the first international instrument to target the “supply side” of the bribery transaction (the person giving the bribe).
Framework Integration:
- CPI (Corruption Perceptions Index): Using Transparency International’s CPI to assign risk weights to different geographic branches. Operations in a country with a CPI score below 40 require “Enhanced Due Diligence” (EDD).
- Internal Control Minimums: Mandating that all international branches maintain “books and records” that accurately and fairly reflect transactions in reasonable detail—a key requirement to avoid FCPA violations.
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