So I may have violated the Foreign Corrupt Practices Act while I was on vacation recently.
Now, for the several readers of these pages who work at the Justice Department, let me state clearly that I’m not sure I violated the FCPA, and this isn’t an episode of self-disclosure. But while on vacation in South America, I had an interesting experience crossing the border into Bolivia that certainly felt like paying a bribe to me. Since FCPA compliance is such a vital part of chief compliance officers’ jobs these days, I wanted to recount the tale here as a from-the-front reminder of what your overseas employees encounter every day.
