Bribes, both foreign and domestic, are often mischaracterized in companies’ books and records. Under this provision, issuers must make and keep books, records, and accounts that, in reasonable detail, accurately and fairly reflect an issuer’s transactions and dispositions of an issuer’s assets.

The Anti-Corruption Tools Exist—Why Aren’t We Using Them?
NWC program manager Jeana Lee explains that proven anti-corruption laws have recovered over $25 billion in sanctions and protect whistleblowers regardless of nationality. But most countries haven’t implemented them—and most…


