Foreign Corrupt Practices Act 2015 Update

Jonathan Barr, John Burke, John Carney, Susrut Carpenter, Kaitlyn Ferguson, Jimmy Fokas, Jonathan Forman, Francesca Harker, Margaret Hirce, John Moscow, Jonathan New, Lauren Resnick, Gregory Saikin, Ned Searby, George Stamboulidis
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Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the Foreign Corrupt Practices Act (“FCPA”). Notable in the first half of 2015 was the SEC’s willingness to look beyond the foreign official bribery provision of the FCPA, as it instituted actions for inadequate internal controls and violations of the FCPA’s books and records provisions against companies including Polycom, BHP Billiton, and Goodyear Tire & Rubber Company (“Goodyear”). In May, the DOJ demonstrated its willingness to go beyond the FCPA’s provisions to tackle foreign corruption. The Fédération Internationale de Football Association (“FIFA”) conspiracy resulted in the DOJ indictment of at least 14 individuals so far for racketeering, wire fraud, and money laundering. As the controversy continues to unravel, it demonstrates the concerted efforts of U.S. and foreign law enforcement authorities. Although the FIFA investigation has not yet resulted in FCPA actions, it provides insight into the DOJ’s willingness to use all available criminal statutes in its crusade against foreign corruption or bribery.

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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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