The past thirty days have underscored the redoubled efforts by the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) to investigate and prosecute violations of the Foreign Corrupt Practices Act (FCPA or “Act”). BAE Systems, Innospec, and Daimler AG have each agreed to large settlements following lengthy investigations by U.S. regulators, often with cooperation from governments abroad. The DOJ has announced that the unit responsible for enforcing the FCPA is set to grow by as much as fifty percent over the next few years, and the SEC’s newly-created FCPA Unit is continuing the SEC’s focus on charging individuals and companies for FCPA violations. All of this underscores that U.S. companies who interact with foreign government agencies or do business in high risk locales must take steps to adopt and enforce strict FCPA policies and procedures or risk costly investigations and significant penalties.
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