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Foreign Corrupt Practices Act: A Firm 's Obligations

March 21, 2011

The Foreign Corrupt Practices Act of 1977, or "FCPA," seeks to prohibit bribery of foreign officials and restore public confidence in the integrity of the American business system.  In this Regulatory Notice, FINRA briefly overviews the FCPA and discusses how its anti-bribery prohibitions affect broker-dealers. A firm that's considered an “issuer” under FCPA, is obligated to comply with FCPA’s accounting provisions - they generally require an “issuer” to make and keep books and records that accurately and fairly reflect the company’s transactions and to devise and maintain an adequate system of internal accounting controls.

FINRA advises member firms to review their business practices and ensure they're in full compliance with the FCPA.  Failure to comply is considered a violation of FINRA Rule 2010, Standards of Commercial Honor and Principles of Trade.

FINRA Contact Person:  Patricia Albrecht in the Office of General Counsel - (202) 728-8026.

For further details, go to:   [FINRA RegNote 11-12, March 2011]

N.B.  C-I will be updating this post later today.  Please visit again.