FCPA and anti-corruption compliance training

For sales, procurement, finance and managers who deal with foreign officials or third parties: recognize bribery risk, apply the FCPA and speak up before a payment goes out.

For: Sales, business development, procurement, finance and accounting staff, and managers who deal with foreign government officials, state-owned enterprises, agents, distributors or other third parties

  • 2 contact hours
  • 7 modules
  • 8 interactives
  • 4 job aids
  • Updated October 11, 2026

What you will be able to do

  • Explain the FCPA anti-bribery and accounting provisions, who they cover and the penalties for companies and individuals.
  • Determine whether a person is a foreign official and whether a gift, trip, hospitality expense or facilitation payment is permissible under the law and a typical company policy.
  • Apply risk-based due diligence to agents, distributors and other third parties, and identify red flags that require escalation.
  • Describe current DOJ enforcement guidelines, the Corporate Enforcement Policy and the Evaluation of Corporate Compliance Programs, and the Foreign Extortion Prevention Act.
  • Distinguish foreign bribery from US domestic bribery, commercial bribery and the UK Bribery Act's broader offenses.
  • Record transactions accurately and report concerns through the right channels without fear of retaliation.

This FCPA training explains how the Foreign Corrupt Practices Act works in day-to-day business: who counts as a foreign official, when gifts, travel and hospitality cross the line, why small facilitation payments are risky, how agents and distributors create liability, and why accurate books and records matter even when no bribe is paid. It also covers the Foreign Extortion Prevention Act, US domestic and commercial bribery laws and a short note on the UK Bribery Act for multinational teams.

It is written for the people who actually face the decisions: the sales director asked to hire a well-connected consultant, the procurement manager whose customs broker wants a "special fee," the accountant asked to book a payment as "miscellaneous." You follow one fictional US manufacturer of industrial pumps through a year of international deals, and practice the calls that prevent problems.

Enforcement priorities changed in 2025: a February executive order paused new FCPA enforcement, and the Department of Justice issued new guidelines in June 2025 that focus on serious misconduct, individuals and harm to US interests. The statute itself did not change. This course separates the law from current enforcement policy, so you understand what stays constant and what to re-check.

What you’ll be able to do Monday morning

  1. Check whether the people you deal with at a customer or regulator include employees of a state-owned enterprise, and treat them as foreign officials if so.
  2. Run your next gift, meal or travel offer to an official through your company's pre-approval process, with the business purpose written down.
  3. List the agents, distributors, customs brokers and consultants on your accounts and confirm each has current due diligence on file.
  4. Refuse to approve any invoice that is vague, round-numbered or paid to an unexpected account until you know what it is for.
  5. Save your company's speak-up hotline details where you can find them in a hurry.

Curriculum

7 modules · 27 lessons · about 2 contact hours

01What is bribery, and how does the FCPA reach your work?Free preview20 min
  1. What do bribery and corruption actually mean?
  2. What does the FCPA prohibit?
  3. Who is covered, and what are the penalties?
  4. What happened next at Redbud?
  • Self-assessment: How exposed is your role to bribery risk?

Diagram · In practice checklist · 3-question knowledge check

02Who is a foreign official, and when do gifts, travel and small payments cross the line?22 min
  1. Who counts as a foreign official?
  2. When are gifts, travel and hospitality acceptable?
  3. What about facilitation payments and extortion?
  4. How do donations, jobs, per diems and other benefits fit in?
  • Decision tree: Can I give this to an official?
  • Spot the issue: Spot the problems in the visit itinerary

Diagram · In practice checklist · 3-question knowledge check

03How do agents and distributors create bribery risk, and what does due diligence look like?22 min
  1. Why are third parties the biggest source of FCPA risk?
  2. What red flags should stop a deal?
  3. What does risk-based due diligence involve?
  4. What about joint ventures, acquisitions and ongoing monitoring?
  • Sort activity: Red flag or normal business?

Diagram · In practice checklist · 3-question knowledge check

04Why do books, records and internal controls matter even when no bribe is proven?20 min
  1. What do the accounting provisions require?
  2. Where do false records usually hide?
  3. What should you do when the numbers do not add up?
  4. How do internal controls show up in daily approvals?
  • Spot the issue: Spot the problems in the subsidiary ledger

Diagram · In practice checklist · 2-question knowledge check

05How has FCPA enforcement changed, and what do prosecutors expect from a compliance program?22 min
  1. What changed in 2025?
  2. What is the Foreign Extortion Prevention Act?
  3. What do prosecutors expect from a compliance program?
  4. What happens in an investigation, and what is your role?
  • Matching activity: What does a working compliance program look like?

Diagram · In practice checklist · 3-question knowledge check

06How do domestic, commercial and UK bribery rules differ, and how do you speak up?22 min
  1. How is US domestic bribery treated?
  2. What is commercial bribery?
  3. What should multinational teams know about the UK Bribery Act?
  4. How and when should you speak up?
  • Branching scenario: A year with a new distributor

Diagram · In practice checklist · 3-question knowledge check

07What does a clean international deal look like from start to finish?18 min
  1. Stage by stage: where did the risks appear?
  2. What made the difference?
  3. Common mistakes, and how to avoid them
  • Ethics dilemma: The internship request

Diagram · In practice checklist · 2-question knowledge check

Final assessment: 23 questions, 75% to pass, then your certificate

Try it now, no account needed

A year with a new distributor

A branching scenario from this course. Your choices are not saved.

Free sample activity

A year with a new distributor

You manage Redbud's sales in a new market. A distributor, recommended by a trade association, passed due diligence and signed a contract with anti-corruption clauses. Sales to a state-owned mining company start well.

Inside the course

Practice activities

  • Self-assessment1
  • Decision tree1
  • Spot the issue2
  • Sort activity1
  • Matching activity1
  • Branching scenario1
  • Ethics dilemma1

Job aids you keep

  • Third-Party Anti-Corruption Due Diligence ChecklistChecklist
  • Gifts, Travel and Hospitality for Government Officials (Starter Policy)Policy starter
  • Anti-Corruption Scenario WorksheetWorksheet
  • US Anti-Bribery Quick-ReferenceReference sheet

Credit and approval status

Certificate of completion

This course awards a certificate of completion for 2 contact hours of instruction. It is not approved for NASBA CPE, state bar continuing legal education or IACET continuing education units, and it is not approved or accredited by any board, state agency or accreditor. The FCPA does not require a specific training course; employers decide what anti-corruption training their compliance program requires. Check with your employer, board or certifying body whether this course meets your specific requirement.

Pathways we may pursue include NASBA CPE sponsorship, state bar CLE accreditation and IACET accreditation. None of these approvals exists today; the course page will show an approval only after it is granted.

Our full approvals list

Questions about this course

Does this FCPA training give CPE or CLE credit?

Not today. You receive a certificate of completion for 2 contact hours of instruction. We may seek NASBA CPE sponsorship, state bar CLE accreditation or IACET accreditation in the future, and the course page will show an approval only if one is granted. If your employer or certifying body needs to review the course, the outline, objectives and assessment details are available on request.

Who should take this anti-corruption course?

Anyone whose work touches international business or government customers: sales and business development, procurement and supply chain, logistics and customs, finance and accounts payable, internal audit, and the managers who approve their expenses. It also helps people who hire or manage agents, distributors and consultants. No legal background is needed; scenarios use plain language.

Is the FCPA still being enforced after the 2025 changes?

Yes. A February 2025 executive order paused new FCPA enforcement while the Department of Justice reviewed its approach, and June 2025 guidelines then set new priorities focused on serious misconduct, individuals and harm to US interests. The statute and its penalties were not repealed, the statute of limitations can reach back years, and other countries continue to enforce their own laws. The course explains what changed and what did not.

How long does the course take and how is it assessed?

Plan on about two hours, including six modules, scenario exercises, short knowledge checks and a 23-question final assessment drawn from a larger bank. You need 75 percent to pass, and many questions are scenarios, so you will need to apply what the modules teach. You can pause and resume at any time.

Does this replace my company's anti-corruption policy training?

No. Your company's own policy, approval thresholds and reporting channels control what you must do at work, and they are often stricter than the law. Use this course to understand the legal framework and the reasons behind the rules, then follow your company's procedures and ask your compliance team when in doubt.

Can I use the job aids in my company?

Yes. The third-party due diligence checklist, gifts and hospitality policy template, scenario worksheet and the US quick-reference are yours to adapt. The policy template is a starter only; have your legal or compliance team review it before you adopt it.

This course is general education and training awareness from CE Courses Hub on anti-corruption and FCPA compliance. It is not legal advice and does not replace your employer's policies, applicable laws in other countries, or advice from qualified legal counsel. Completing it earns a certificate of completion for the stated contact hours; it is not approved or accredited by any licensing board, state agency or accreditor unless an approval is shown on the course page. Check with your board, employer or state agency whether this course meets your specific requirement.