Bass, Berry & Sims attorneys Wally Dietz and Lindsey Fetzer co-wrote the article “How-to Manual on Creating and Maintaining an Anti-corruption Compliance Program,” that was published in the June 2015 issue of ACC Docket. The article was co-authored by Kristen Collier Wright, the senior vice president, general counsel and secretary, customer satisfaction at AutoZone, Inc. This article provides a detailed step-by-step approach to designing and implementing an anti-corruption compliance program, including:

  • Step 1: Senior management decides to develop and implement a compliance program
  • Step 2: Risk assessment
  • Step 3: Design of the compliance program
  • Step 4: Implementation
  • Step 5: Enforcement
  • Step 6: Monitoring and evaluation
  • Step 7: Responding to potential compliance issues

The full article, “How-to Manual on Creating and Maintaining an Anti-corruption Compliance Program,” is available on the ACC Docket website (subscription required) or in the PDF link below.