Noatum Logistics Completes Acquisition of the Multinational MIQ Logistics. Read more.

Accounting Provision (no secret accounts)

The FCPA requires keeping books, records and accounts in reasonable detail that accurately and fairly reflect the transactions and dispositions of the company.

  • The “cardinal rule” of an FCPA–compliant accounting program is documentation of expenditures.
    • At a minimum, every marketing expense, facilitating payment, etc… should be documented and cash payments should be discouraged.
  • Maintain an internal accounting system assuring that –
    • transactions are executed and assets are disposed of only in accordance with management’s authorization
    • transactions are recorded to meet GAAP
    • periodic audits of existing assets