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Internal Auditing for FCPA & Anti-Corruption: Leading Practice Considerations from the SEC and DOJ Guidance

Course Description

Print-friendly Course Description and Outline

​Internal auditors can provide high value services to audit committees, boards and senior management by evaluating and enhancing an organization’s anti-corruption and FCPA compliance program.

Compliance with anti-corruption laws such as the U.S. Foreign Corrupt Practice Act (FCPA) has been a growing focus of many organizations due to increased business activity in emerging markets, and an uptick in FCPA enforcement and fines that often reach hundreds of millions of dollars. In addition, the Dodd-Frank Act in July 2010 created rewards of 10 to 30 percent of monetary recoveries for whistleblowers who report potential securities law violations to the U.S. Securities and Exchange Commission (SEC). The SEC was reported to be receiving an average of one FCPA tip each day.

This interactive one-day course, a joint effort between The IIA and Deloitte & Touche, will provide an overview of the FCPA and UK Bribery Act and will discuss the various roles internal auditors can play in auditing for corruption. The course will also enable participants to:

  • Assess your organization’s risks related to corruption,
  • Detect common corruption schemes and red flags,
  • Recognize elements of an effective anti-corruption and FCPA compliance program.
  • Design internal audit steps to evaluate such programs.
Course Duration: 1 day(s)
CPE Hours Available: 8
Knowledge Level: Intermediate
Field of Study: Auditing


Advance Preparation: 


Delivery Format: On-site Training (Group-Live)

​Overview of Fraud, the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and Recent Trends

  • Overview of occupational fraud and the corruption triangle
  • Overview of the FCPA and discussion on the key components of the anti-bribery and books and records provisions
  • Overview of the U.K. Bribery Act and key differences between the FCPA and the UK Bribery Act
  • Global trends in anti-corruption enforcement
  • Discussion of roles of Internal Auditors in auditing for Corruption

Corruption Audit Procedures

  • Discussion of initial planning considerations
  • Areas to consider in the audit
  • Potential red flags to look for in high-risk areas
  • Potential interview topics/themes
  • Potential audit procedures
  • Detail testing
  • Technology
  • Due diligence

M&A Due Diligence

  • Overview of role and key considerations
  • Areas to consider in due diligence reviews

Corruption Risk Assessment

  • Discussion of initial planning considerations
  • Quantitative and qualitative factors to consider
  • Steps in performing a risk assessment
  • Use of technology in a risk assessment
  • Other considerations in the risk assessment

Elements of an Effective Compliance Program

  • Overview of anti-corruption compliance programs
  • Elements of an effective program
  • Evaluating the design and implementation of program elements

Responding to Red Flags

  • Planning and coordinating with compliance and legal function
  • Identifying when an internal audit should become an investigation

​Most courses can be delivered through on-site training. You might be surprised that the organization leading the profession is just as committed to the delivery of affordable training.

Contact us by calling +1-407-937-1388 or send an e-mail to