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What are the internal accounting requirements for an issuer under the Foreign Corrupt Practices Act (FCPA)?

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What are the internal accounting requirements for an issuer under the Foreign Corrupt Practices Act (FCPA)?

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The internal accounting requirements of the FCPA require an issuer to provide reasonable assurances that (1) transactions are executed in accordance with management’s general or specific authorization; (2) transactions are recorded as necessary to permit preparation of financial statements in conformity with generally accepted accounting principles or any other criteria applicable to such statements, and to maintain accountability for assets; (3) access to assets is permitted only in accordance with management’s authorization; and (4) the recorded accountability for assets is compared with the existing assets at reasonable intervals and appropriate action is taken with respect to any differences.

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