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Scrutinizing hiring practices for FCPA violations

Jaclyn Jaeger | March 15, 2016

The Securities and Exchange Commission and Department of Justice have been warning companies to proceed with caution when hiring the relatives of foreign government officials, lest they run afoul of the Foreign Corrupt Practices Act.

Hiring a relative or friend of a government official does not, in itself, constitute an FCPA violation. What the SEC and the Justice Department will take issue with is when the intent of that employment is an indirect method of providing something of value to a government official to obtain or retain business.

Kristy Grant-Hart“Perhaps in the past people didn’t think of internships or jobs as a thing of value that could trigger an FCPA investigation,” says Kristy Grant-Hart, managing director of Spark Compliance Consulting and former chief compliance officer of United...

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