How do you control bribery? If you haven't heard yet, the government is in the midst of a massive crackdown on overseas bribery. Financial Week reports that the Department of Justice has initiated more enforcement actions in the last year and a half than during the six years from 2000 to 2005. Oil companies have borne the brunt of that effort. Bribery is a tricky area that falls under the Foreign Corrupt Practices Act. Is it in-scope for Sarbanes-Oxley? I would say yes. A lot of bribery is apparently conducted via third-parties to give executives deniability. It's fair to say that activity via subsidiaries, suppliers and other third-parties has received a lot of attention. At a minimum, you would expect auditors to ask some questions. But all in all, if a company really wants to bribe, it will be hard to control.   

For more:
- here's the Financial Week article

Related Article:
E&Y: Bribery on the rise