On March 18th, FINRA reminded its members of their obligations under the Foreign Corrupt Practices Act. Member firms that are considered to be "issuers" under the FCPA must comply with the FCPA's accounting provisions, which generally require an "issuer" to make and keep books and records that accurately and fairly reflect the company's transactions and to devise and maintain an adequate system of internal accounting controls. A member firm's failure to comply with its FCPA obligations will be considered conduct inconsistent with high standards of commercial honor and just and equitable principles of trade in violation of FINRA Rule 2010. FINRA Regulatory Notice 11-12.