FCPA violations in China: Lessons learned from 2023 cases
By 
Aaron Nicodemus2024-01-25T18:01:00
Third parties in China are at high risk of participating in bribery schemes with government employees. U.S. regulators have prosecuted violations of the Foreign Corrupt Practices Act (FCPA) in China more than any other country by a significant margin.
There have been 117 FCPA cases since 1978 involving violations in China prosecuted by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC), according to statistics compiled by law firm Gibson Dunn. Nigeria (77) was a distant second, followed closely by Mexico (67), Brazil (60), Indonesia (53), and Iraq (51).
This is not to say corruption in China is worse than the other countries, said Kelly Austin, a Gibson Dunn partner, in a recent webcast held by the firm on FCPA enforcement trends in emerging markets.
Related articles
-
PremiumBridging cultures: Adapting corporate compliance to APAC norms
’Tis the season of giving. For multinationals, compliance in gifts and entertainment policies in Asia is not about exporting Western rules, but embedding global standards in a language and culture local teams trust.
-
PremiumThe path to DOJ cooperation credit: Analyzing recent FCPA cases
Recent enforcement actions offer guidance on what the Department of Justice considers to be an “imminent threat” of disclosure or government action, what it means by “prompt” disclosure, and how a company can earn credit for revealing all relevant facts.
-
News BriefCalavo Growers discloses potential FCPA issues
Multinational produce and agriculture company Calavo Growers disclosed in an annual filing an investigation into its Mexico operations found potential issues under the Foreign Corrupt Practices Act.
More from Regulatory Enforcement
-
ArticleSan Francisco firm pays $11.4M for alleged Russia-related sanctions violations
A San Francisco-based private equity firm has agreed to pay $11.4 million to settle allegations it violated U.S. sanctions rules by handling investments for a sanctioned Russian oligarch.
-
ArticleCompany agrees to report to FTC for 10 years for alleged student data lapses
A tech company that stores student information for schools has agreed to implement a data security program and report to the Federal Trade Commission for 10 years, after security failures led to data for 10 million students being breached.
-
ArticleLarge wound care practice pays $45M, agrees to monitoring
One of the largest wound care practices in the nation and its founder have agreed to pay $45 million and be subjected to third-party monitoring, to settle allegations that the business intentionally overbilled Medicare by priming its electronic medical records system to do so.