In the Guidance issued by the Department of Justice and SEC (Guide) and some of the various FCPA settlement documents, the government has provided guidance on what elements are essential for an effective anti-corruption compliance program. This is a significant development from previous uncertainty in this area when companies were in the position of having to rely on (often cryptic) press releases and speeches or public statements from government officials in determining what the DOJ or SEC would view as a good compliance program. This new guidance provides companies with a more specific and concrete model of what the government expects from their compliance programs. Virtually all of these “tips” are also informative for building non-FCPA compliance programs.