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Remember Four Key FCPA Facts

  • FCPA also applies to Non-U.S. Companies
    Recent FCPA investigations concern business activities by non-U.S. companies that occur outside the United States. Ignoring the FCPA regulation creates danger even for foreign corporations.
  • FCPA applies to both; public and private companies
    Several recent FCPA enforcement actions concern foreign business activities by private U.S. companies. It is important to create an FCPA policy and document the rules of interaction with privately held organizations, state owned enterprises and their representatives, including tracking expenses.
  • FCPA applies when doing business with employees of State Owned Enterprises
    The employees of State Owned Enterprises fall under the definition of a Foreign Official. It is imperative to Know Your Customer and Business Partners around the world. All customers and business partners should be risk rated, based on several factors including the location of the third party, the industry the company is involved in, and the business practices of said organization.
  • FCPA applies when an agent or distributor bribes a government official
    Corporations cannot insulate from the FCPA requirements by teaming up with agents or distributors. It is important to share a written policy with all business partners and ask that they adhere to your FCPA policy. Ensure that books, records and accounts are kept in reasonable detail to accurately and fairly reflect transactions and dispositions of assets.