You Are a Non-U.S. Company - Why Should You Care about the U.S. Foreign Corrupt Practices Act?

The long arm of U.S. law can be seen clearly in recent enforcement of the Foreign Corrupt Practices Act or FCPA, a criminal law prohibiting bribery of non-U.S. government officials. Companies whose operations even remotely touch the U.S. and who therefore could come within the FCPA’s jurisdiction should consider implementing anti-corruption compliance programs to prevent, detect, and remediate violations. Such programs can be a key mitigating factor in U.S. regulators’ decisions whether to bring an enforcement action or in the penalties sought if an action is brought.