Books and records
Issuers, etc.* are required to make and keep detailed books, records, and accounts that fairly and accurately reflect transactions and dispositions of assets.
Internal accounting controls
Issuers, etc.* must devise and maintain internal accounting controls to ensure that financial records and accounts are accurate for external reporting, that access to assets is permitted only in accordance with management instructions, and that the books are audited at reasonable intervals.
Importance of these two aspects of the FCPA:
More readily established than the payment of a bribe
Sarbanes-Oxley requires disclosure of deficiencies in internal controls and fraud, audit committee oversight, and increased legal scrutiny all triggered by corrupt payments.
* Wholly-owned and majority owned subsidiaries must comply.