What do anti-bribery laws like the FCPA and UK Bribery Act require, and what are 'adequate procedures'?

These laws prohibit corruption with extraterritorial reach. The US FCPA prohibits bribing foreign government officials and requires accurate books-and-records and internal accounting controls (the latter catches far more cases than actual bribery). The UK Bribery Act is broader: it covers commercial (private-to-private) bribery as well as officials, prohibits offering and receiving bribes, and crucially creates a strict-liability corporate offense of 'failure to prevent bribery' by an associated person. The only defense to that offense is having 'adequate procedures' — proportionate, risk-based anti-bribery controls: top-level commitment (tone from the top), risk assessment, proportionate due diligence on third parties/agents (a common bribery channel), clear policies and gifts/hospitality rules, training and communication, and monitoring and review. Practically, firms run third-party due diligence, control facilitation payments (legal under FCPA in narrow cases, illegal under UK law), and document the program — because under the UK regime the program is the defense. Penalties (fines, debarment, individual liability) are severe, so it's a board-level compliance priority.