Travel Act: buttressing the FCPA


Originally published in the San Francisco Daily Journal on October 1, 2012.

Much attention has been given to the Department of Justice’s investigation and prosecution of overseas corruption under the Foreign Corrupt Practices Act (FCPA) — and deservedly so. In 2011, the DOJ collected over a half-billion dollars in FCPA penalties and disgorgement, marking four consecutive years in which collections exceeded that amount — including the record amount of $1.8 billion in 2010.

As the DOJ has made clear, however, the FCPA is not the only statute at its disposal for prosecuting overseas corruption. U.S. companies should be familiar not only with the FCPA, but also with the mail and wire fraud statutes. 18 U.S.C. Sections 1341 and 1343. Companies should also be familiar with the Travel Act. 18 U.S.C. Section 1952. When combined with the FCPA, the DOJ has used the Travel Act to reach both public and commercial bribery abroad.

Please see full alert below for more information.

LOADING PDF: If there are any problems, click here to download the file.

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.

© Morrison & Foerster LLP | Attorney Advertising

Written by:


Morrison & Foerster LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.