Despite the onslaught of anti-bribery and anti-corruption enforcement actions, it appears that some companies may not be taking recent warnings to “know thy customer” to heart just yet.

Most multinational U.S. companies have programs in place to meet Foreign Corrupt Practices Act guidelines. However, they still may not know enough about those with whom they do business in other countries, according to the results of a survey of 103 executives by KPMG.

Among the 103 U.S. executives who identified themselves as having day-to-day responsibility for FCPA matters, 85 percent said their company had a formal FCPA or anti-corruption compliance program, KPMG reports. Perhaps that’s not surprising, given that the firm says at least 80 companies have been investigated for potential FCPA violations in 2008, up from 29 in 2007.

However, KPMG notes that only about 40 percent have periodic anti-bribery and anti-corruption compliance certifications, and of that group, most don’t extend that requirement beyond their employees. Only 32 percent of that group reported requiring FCPA compliance certifications from their agents, and just 24 percent required them from their vendors and suppliers, according to KPMG.

While 63 percent of respondents that require periodic compliance certifications said they incorporate a right-to-audit clause in their third-party contracts, most of that group (68 percent) has never exercised the right.

Notably, KPMG says a right-to-audit clause “appears to be the kind of oversight expected by regulators and prosecutors and has been included as an essential element of FCPA compliance in several recent deferred or non-prosecution agreements that companies have reached with the Securities and Exchange Commission and the Department of Justice.”

For example, KPMG notes that recent agreements entered into in 2008 included stipulations that the parties agree to adopt new or modify existing procedures to include “rights to conduct audits of the books and records of” agents or business partners “to ensure compliance” with anti-bribery laws and regulations.

Moreover, 82 percent of those polled say they still wrestle with performing effective due diligence on foreign agents and third parties and 78 percent say they have trouble identifying and assessing FCPA risk. More than three-quarters of respondents said they couldn’t adequately audit third parties for compliance, and 73 percent said their mergers and acquisition due diligence was sub par, KPMG reports.