Regulators Take Aim at Acts of Foreign Bribery: Heightened Necessity for Foreign Corrupt Practices Act Compliance Programs and Procedures
Recently, the number of Foreign Corrupt Practice Act ("FCPA")-related investigations by the Department of Justice and the Securities & Exchange Commission has spiked dramatically — and violators are facing multi-million dollar penalties. In view of the enormous risks of non-compliance with the FCPA, every company doing business in the United States or selling stock in the United States (including ADRs) should have a clear FCPA policy and a robust FCPA compliance program.