Foreign Corrupt Practices Act (FCPA) enforcement continues to be a priority for the United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC). In recent years, U.S. authorities have aggressively investigated and charged corporations and individuals for foreign bribery and related conduct. FCPA investigations can be extremely expensive, and resolving enforcement actions is often very costly in terms of direct fines and penalties, as well as collateral consequences.

Anti-corruption enforcement is increasingly global in scope. A number of countries outside the U.S. have recently passed their own international anti-corruption laws, and more nations are aggressively enforcing their domestic anti-corruption legislation, leading to vigorous multinational anti-corruption enforcement often targeting Western companies. Employees around the world are potential sources of corruption allegations, particularly after the advent of the SEC whistleblower program in 2011.

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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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