Anti-Corruption and Privacy Laws – Collision Course?

More and more companies are implementing due diligence processes for engaging third parties. Although companies adopt these processes in order to reduce the risks of violating anti-corruption laws, such as the U.S. Foreign Corrupt Practices Act (“FCPA”) and the UK Bribery Act 2010 (“UK Bribery Act”), their due diligence programs may unwittingly expose them to risks under privacy and data protection laws around the world. Complying with both anti-corruption and privacy laws can be challenging, but can be accomplished.

Anti-corruption laws of various countries, including the FCPA and the UK Bribery Act, criminalize bribing foreign government officials and create certain compliance obligations for global companies—even in jurisdictions that do not have their own anti-corruption laws.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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