# Anti bribery compliance
> Source: https://legalcode.md/skills/legalcode-anti-bribery-compliance | [HTML version](https://legalcode.md/skills/legalcode-anti-bribery-compliance)

Assess, build, or remediate an organization's anti-bribery and anti-corruption (ABAC) compliance program against the major international regimes: US Foreign…

Assess, build, or remediate an organization's anti-bribery and anti-corruption (ABAC) compliance program against the major international regimes: US Foreign Corrupt Practices Act (FCPA) anti-bribery provisions, books-and-records, and internal controls requirements; UK Bribery Act 2010 including the Section 7 corporate offence and adequate procedures defense; France Sapin II (Law No. 2016-1691) mandatory compliance program obligations and Agence Française Anticorruption (AFA) guidelines; and Brazil Clean Company Act (Lei 12.846/2013). Use when reviewing an existing ABAC program for gaps, building a new program from scratch, preparing for regulatory examination or enforcement response, conducting third-party due diligence, drafting or reviewing gifts-and-entertainment policies, designing government-official interaction protocols, or evaluating a specific transaction or red flag for corruption risk. Triggers on: "FCPA compliance," "UK Bribery Act," "Sapin II program," "anti-bribery," "anti-corruption," "adequate procedures," "third-party due diligence," "gifts and entertainment policy," "facilitation payments," "DOJ FCPA guidance," "SFO prosecution," "AFA audit," "government official interaction."

This skill assesses organizations' anti-bribery and anti-corruption (ABAC) compliance programs, identifies gaps against four major regulatory regimes, and produces a prioritized remediation roadmap. **Covers:** - Full ABAC program assessment across FCPA, UK Bribery Act 2010, Sapin II, and Brazil CCA - Multi-regime gap analysis with jurisdiction-specific classification - Third-party due diligence program review - Gifts, entertainment, and hospitality policy assessment - Government-official interaction protocol review - Books, records, and internal controls assessment (FCPA) - Adequate procedures analysis (UK Bribery Act) - Mandatory program components audit (Sapin II / Brazil CCA) - Transaction-specific corruption risk assessment - Confidence-scored findings with Glass Box audit trail **Does not:** - Provide legal advice or replace qualified anti-corruption counsel - Substitute for external forensic investigation or privilege-protected internal review - Assess sanctions, export controls, or AML compliance (see dedicated skills) - Apply exclusively to one jurisdiction — multi-regime with [JURISDICTION-SPECIFIC] markers This is a multi-jurisdiction skill covering four primary regimes with global extraterritorial reach. Unlike contract-review skills, governing law is not determined by a single clause — multiple regimes may apply simultaneously. | Regime | Territorial Scope | Key Trigger | |--------|------------------|-------------| | **FCPA** (US) | US persons and issuers everywhere; foreign companies with US ...

## Jurisdictions

Global



---
*Legalcode -- legalcode.md*