FCPA: Developments in Global Anticorruption Enforcement
Aggressive prosecutions and enforcement actions by the U.S. government for violations of the Foreign Corrupt Practices Act (FCPA), first enacted in 1977, are continuing at record pace and multinational companies continue to face enormous scrutiny of their overseas business practices in the U.S and abroad. Further, there have been several developments in anticorruption enforcement in the last few years, including significant FCPA settlements, a new UK Bribery Act and guidance by the U.K. government regarding what constitutes “adequate procedures” that could provide covered companies with a complete defense to bribery charges.
- The components of an effective FCPA compliance program and whether it can aid in avoiding corporate prosecution;
- Whether your compliance program will protect your company from rogue employees;
- Whether your compliance program is evolving with new regulatory developments and industry guidance; and
- When, if ever, to involve outside counsel if bribes are suspected.