1. The document outlines best practices for mitigating risks associated with compliance with the Foreign Corrupt Practices Act (FCPA) in China, including monitoring compliance programs, internal controls, education and training, and due diligence. 2. Key recommendations include monitoring business processes, implementing accounting controls to prevent deceptive record keeping, and providing culturally sensitive training to employees and business partners. 3. If misconduct is suspected, companies should secure evidence, notify legal resources, and consider potential exposure under Chinese law since privileges may not be recognized.

1. Foreign Corrupt Practices Act in China Compliance Strategies Given China's Unique Cultural and Governmental Intricacies Best practices for mitigating risk Amy L. Sommers Shanghai March 3, 2011