New York Times columnist David Brooks’ thoughts on building and maintaining order inform the discussion on rigor in your internal controls. In internal controls, I believe it is incumbent to consider not only the most obvious risk areas for your internal controls but also the universe of potential transactions within the operations of a company. There is a clear need for rigor in your internal controls protocols and adherence to that rigor can increase operationalization around the internal controls a company should consider including gifts, travel and entertainment expenses. Brooks said, “Building and maintaining order … requires toughness of mind and rigid discipline to properly serve your own work.” By having the rigor to institute and enforce the types of internal controls identified, you can go a long way towards detecting and, more importantly, preventing a FCPA violation from occurring.
Some of the key areas of Internal Control focus should be: 
·       The Delegation of Authority (DOA) 
Petty cash disbursements 
·       Travel 
·       P-Cards
·       Employee Expense Reports 
·       Corporate checks and wire transfers, such as check requests, purchase orders, or vendor invoices.
·       Gifts and business entertainment
 Three key takeaways:
1. You must maintain rigor around your internal controls.
2. Controls against fraud can also help to prevent corruption.
3. Building and maintaining good internal controls requires rigor.
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