I'm not really sure if this is the appropriate forum, but I was curious as to what, if anything, other community banks are doing to comply with the FCPA? A multinational vendor who were considering doing business with is inquiring how we comply with the FCPA. This seems somewhat unusual given the current asset size of my current shop (One branch and around $200 million).

Would any one be willing to share what, if anything, is being done to demonstrate compliance with the FCPA? Or is this just an exercise in futility for a small, domestic bank?

You might want to read this article from ABA issued a couple of years ago:
https://www.aba.com/Products/bankcompliance/Documents/MarchApr11CoverStory.pdf

For the most part, a small domestic bank is an FCPA non-event but you may want to go through the article to see if anything applies to your shop.

Thank you PR.

In the past we just had a policy that explained the act and that all employees are subject to it.

We have been asked about policy when they review Gift Logs.

A multinational vendor who were considering doing business with is inquiring how we comply with the FCPA.

this part had me puzzled as what do they expect or are they planning to offer bribes?

No, the vendor wanted us to confirm we have a FCPA Policy, procedures, processes, etc.