FCPA Other Penalties / Sanctions

Other government penalties that apply are:

  • Suspension or debarment from securing contracts with the government.
  • An indictment can lead to suspension.
  • The suspension or debarment of a business by one government agency disqualifies it from contracting with any other government agency.

Private lawsuits

  • No private rights of action.
  • Securities class actions or shareholder derivative suits.
  • Lawsuits based on antitrust laws and common law prohibitions due to contract and unjust competition.