Purpose

• The purpose of having an FCPA training program is to educate employees, who in the eyes of the law, act as agents for their employers, on what constitutes bribery under its legal definition. For example, an employee may think taking a foreign official out to dinner to discuss business is permissible, but under the FCPA this act could be considered bribery.
  
  

Scope

• Employers should mandate that any employee working overseas, or with an overseas client, complete the company's FCPA training program. Employers should also inquire as to whether contractors or other third parties they work with have completed a FCPA training program.
  
  

Materials

• To complement an FCPA training program, employers should develop a reference manual employees may consult as needed. Law firms and attorneys specializing in the FCPA can assist in the development of a specialized manual. Online FCPA training courses are also available.