Corporate cultures do not have a choice whether or not to implement FCPA. The United States and other countries have a strict no-nonsense attitude toward business corruption and bribery. Compliance officers must gure out how to integrate an effective FCPA program complete with operating procedures, employee education, contractor education and detailed record keeping. \"Organizations with organized, well-integrated, multilayered compliance programs evidencing fiduciary responsibility and due diligence position themselves to defend against accusations of corruption (Aguilar. 2010].\