Thailand: Third Fundamental Element of Internal Control Measures under the NACC’s Guidelines

In our previous article (link), we analyzed the second fundamental element under the National Anti-corruption Commission (NACC)’s guidelines, which is “the risk assessment to effectively identify and evaluate exposure to bribery.” In this article we will discuss the third fundamental element, namely “enhanced and detailed measures for high-risk and vulnerable areas.”
 
Companies should have detailed measures in place for high-risk and vulnerable areas that may be implicated in a bribery case. These areas, which include facilitation payments, hospitality expenditures and gifts, and charitable and political donations, are considered high-risk and vulnerable areas because it is difficult to see whether they are expenditures for a traditional, customary, or cultural occasion, or on an occasion…