AbstractDue diligence in corporate transactions can be a major project undertaken with significant time constraints. Acquiring companies will ordinarily conduct detailed reviews of target companies' finances and contracts. Depending on the size and significance of the acquisition, there may be dozens of other issues delved into during the due diligence process. As part of this process, acquiring companies must not overlook an assessment of whether the target company has knowingly made corrupt payments to foreign officials to obtain or retain business that would constitute violations of the Foreign Corrupt Practices Act (FCPA).