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The new trend in FCPA compliance is cooperation

Harold Kim | October 3, 2017

For any corporate leader, a letter from the Department of Justice or SEC announcing an inquiry into an employee’s or contractor’s interactions with foreign officials can be about as welcome as a call from your doctor to come see him about the results of your recent medical test.

For 40 years, the Foreign Corrupt Practices Act has made it a serious crime to use bribery to win a business advantage from foreign officials. Violations have resulted in tens of millions of dollars in fines. Executives have been hit with stiff prison sentences. Corporations have been forced to spend millions of dollars—even hundreds of millions of dollars—defending themselves.

Yet bribery rarely begins as a corporate-level initiative, at least among U.S. companies. It is most often the result of a misguided or rogue individual or contractor. The impact of a bribery investigation, however, is virtually always felt at the corporate level. That’s one reason why U.S. corporate leaders have not... To get the full story, subscribe now.