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The Anti-Corruption Compliance Benchmarking Survey Report Is Now Available

Rebecca Walker and I are very pleased to announce that the report based on the benchmarking survey that we and the FCPA Blog conducted earlier this year of corporate anti-corruption compliance programs is now available. 

Participants in the survey will soon be receiving their complementary copies of the report and others may order copies from the report’s sponsor, Ethics360 ( The report is also available at no charge to government officials and full-time academics.

More than 100 companies took part in the survey and the results should, we believe, prove helpful to many organizations seeking to assess or improve their programs.  A sampling of data includes the following:

  • One third of respondents utilize a stand-alone, documented risk assessment process dedicated solely or largely to Anti-Corruption risk.
  • Forty-three percent require some third-party intermediaries (“TPIs”) to certify periodically that they are in compliance with Anti-Corruption laws; 27% do so for all TPIs.
  • More than half have formal standards for monitoring compliance by TPIs - such as requirements that, on an ongoing basis, business personnel review TPIs’ invoices to ensure that they do not suggest violations of Anti-Corruption laws.
  • About two thirds have formal Anti-Corruption compliance integration procedures of acquisitions and joint ventures.
  • Only 4% have not designated a senior company official to oversee the Anti-Corruption compliance program.
  • Three out of every eight companies conduct stand-alone Anti-Corruption audits.

The survey consisted of 48 questions, so this is only a small fraction of the data available in the report – which also covered in considerable detail topics such as gifts, entertainment and travel; charitable contributions and community support payments; facilitating and personal safety payments; a wide variety of other matters concerning TPIs; board of directors anti-corruption compliance program oversight; training and communications; self-assessments; compliance incentives; and program documentation.


Jeffrey M. Kaplan, a partner in the Princeton, New Jersey office of Kaplan & Walker LLP, has practiced in the compliance law field since the early 1990’s. He serves as Adjunct Professor of Business Ethics at NYU’s Stern School of Business. He can be contacted here.

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