- Creating a compliance policy is essential but it is not enough to satisfy a possible anti-bribery investigation.
- Organizations need to prove that they are following those polices by incorporating compliance into the DNA of their company as a good business practice
- “Tone from the top" is important; "tone from the middle" which actively engages directors, managers and lines of business is as, if not more important
- Effective internal controls ensure your program is working the way it's designed to - pay attention to those areas of your business which present the highest risk
- Third party relationships;
- Travel gifts and entertainment;
- Sales agents and distributors/commission rates;
- Bartering and free promotional products.
- Use appropriate technology as an integrated component of your compliance program – to ensure consistency, objectivity, audit trail and a single book of record of all anti-bribery activity that is essential for an audit.
WTF Is Going On with NFA – A Must Read
The Silencer Shop v. ATF ruling is historic, but it’s not the end of the NFA for everyone. Here’s who’s actually covered, and the compliance gap most FFLs haven’t spotted yet.






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