Privileged and Confidential
Sample Questions
1. Are staff aware of FCPA and what constitute violations?
2. Are there contracts with government-related entities and/or officials?
3. Are any customers of the company related to any government official? Do any customers
have relationships with the army/military in the country?
4. Were any payments, gifts and/or other valuables (goods and/or services) offered or made to
Government officials or people related to government officials? If so, what was the
value/amount, the purpose and how were these transactions recorded?
5. Are any suppliers of the company related to any government official?
6. Are any family members (i.e., of sales representatives, agents, suppliers/customers,
employees) government affiliated?
7. Has the company paid for any travel, expense reimbursement or entertainment of any
government-related entities and/or officials?
8. Do the company use or retain agents? If so, what services do they perform and what type of
due diligence is performed on sales representatives / agents / intermediaries, prior to
retention?
9. Do agents make payments on behalf of the company and subsequently seek reimbursement?
10. If agents/consultants are used did they ever:
a. state that a particular amount of money is needed to “get the business,” “make the
necessary arrangements,” or some comparable expressions;
b. ask to have invoices backdated or altered;
c. ask to be over-invoiced;
d. ask to have payments made to “bearer” or “cash”
e. ask to have payments made to a foreign country
11. What are the various touch points with government? Does the company have any dealings
with government authorities eg. Tax filing, obtaining business license/permit, obtaining visa
for employees etc. Describe dealings and whether any payments had to be made and purpose
for such payments
12. Is there a need for company to entertain or maintain relationships with government?
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