Global Sourcing Logistics: How to Manage Risk and Gain Competitive Advantage in a Worldwide Marketplace

4. Develop specific SOPs to incorporate into operating

guidelines and ensure compliance.

5. Issue internal communications from senior manage-

ment with nontolerance and strict penalty guidelines.

6. Initiate annual audits by outside consultants, law firms,

and specialists to analyze potential FCPA violations.

7. Establish internal resources and call centers in the event

an executive needs assistance in dealing with a potential

FCPA violation or potential problem situation without

threat of backlash.

8. Identify high-risk situations, countries, customers, etc.,

that may become involved in an FCPA violation and

proactively mitigate these situations.

9. Work with internal risk management personnel to de-

termine insurance options and alterative loss control ...