This Practice Note discusses the provisions of the Corruption of Foreign Public Officials Act, S.C. 1998, c. 34 and leading cases. The Note also focuses on corporate liability, the scope of middle managers and corporate compliance. This Note develops the concept of a risk-management matrix, which has been applied on a global scale. The matrix will assist an organization in identifying the appropriate level of auditing and training that will be necessary in a given situation. The recent decision of the Ontario Superior Court in R. v. Arapakota, (2023) is also discussed.