This audit program sample assists audit teams reviewing compliance with the Foreign Corrupt Practices Act of 1977 (FCPA). It includes general and distinct tests that can be modified to reflect the specific plans and special administration attributes of an organization.

Established well before the Sarbanes-Oxley Act of 2002 (SOX), the FCPA required management to maintain a system of internal controls that provided “reasonable assurances” that transactions were authorized and in accordance with general audit and accounting principles (GAAP). Controls covered span several internal functions and external organizations' international dealings, cash payments, vendor arrangements and ethics programs.