Challenge of addressing FCPA Compliance

The U.S. Foreign Corrupt Practices Act (FCPA) aims to combat bribery and corruption. It establishes liability for corporations regarding bribery payments and third-party oversight. The U.S. Securities and Exchange Commission (SEC) and the U.S. Department of Justice (DOJ) both aggressively enforce the FCPA to encourage fair business practices on a global scale. The DOJ expects a risk-based compliance program that applies greater resources and due diligence for the areas at highest risk in your organization. In addition, senior management is expected to go beyond internal controls by creating a tone from the top that embeds a culture of FCPA compliance throughout the organization.  

Fines for FCPA violations frequently are in the hundreds of millions of dollars category with the heftiest fine nearing $1 billion. The company is not the only entity at stake when violating FCPA compliance. Individual employees across all levels of the organization can be hit with civil enforcement actions that can result in significant civil penalties as well as disgorgement of profits gained from corrupt practices. Since 1977, FCPA has been one of the most prominent anti-corruption acts facing organizations and continues to remain a significant concern to ethics and compliance programs globally. 

Corruption Enforcement Continues to Increase

Ongoing global enforcement with implications to both organizations and ownership

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Additional FCPA Insights 

A high level overview of the most pertinent anti-bribery and anti-corruption (ABAC) developments of 2022 and early 2023
Anti-bribery guidelines prevent people and organizations from attempting to bribe others, while anti-corruption guidelines prevent public officials from accepting those bribes. 
The Russian Federation’s unprovoked, unilateral decision to occupy Ukraine in February 2022 set the stage for comprehensive sanctions to be imposed by global governments against the Putin regime. 
Sanctions have been on everyone’s radar of late, and with companies needing to comply with sanctions against Russian companies and individuals, the benefits of sanction screening are becoming better-known.