To embed, copy and paste the code into your website or blog: Today, I conclude my five-part series on a Primer on FCPA Compliance. I end with a piece on policies and procedures. There are numerous reasons to put some serious work into your policies and procedures. They are certainly a first line of defense when the government comes knocking. The 2020 FCPA Resource Guide made clear that “Whether a company has policies and procedures that outline responsibilities for compliance within the company, detail proper internal controls, auditing practices, and documentation policies, and set forth disciplinary procedures will also be considered by DOJ and SEC.”