Page 168 - CFF
P. 168

FCPA investigations (continued)






         FCPA requirements


         • Recordkeeping and internal control requirements

            – Adequate detailed recordkeeping

            – System of internal controls to ensure the following:

                – Reasonable assurances that transactions are executed in accordance with management’s
                    authorization

                – Asset recording and accountability for producing correct financial statements
                – Limiting access to assets to management’s authorization

                – Recorded accountability for assets is periodically compared to existing assets and
                    appropriate actions are to be taken for deviations








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