Company books and records must be accurate. Off-the-books accounting, "slush funds," and falsification of records to cover up acts of bribery are violations of the FCPA.
In addition to prohibiting bribery itself, the FCPA requires companies to maintain a system of internal accounting controls to ensure that transactions are properly recorded.
Do not attempt to cover up a questionable payment. Doing so will only make the problem worse. For example, under the FCPA, the penalties for covering up an improper payment to a government official can be more severe than the penalty for the initial payment itself.
Consult the company's anti-bribery policy for additional information on recording and reporting expenses related to dealings with government officials.