International Bribery Rules Have Changed: Is your FCPA policy up-to-date?


Last week's International Law conference in New York focused a great deal of attention on the Foreign Corrupt Practices Act. If your business operates in more than one country, you may find the following key takeaways from the conference valuable to review.

1) FCPA investigations and enforcement is being significantly increased by the DOJ and the SEC, and both agencies expressed the determination to increase criminal prosecutions against individuals.

2) The UK just passed an FCPA of its own. The gist of it is this:

-the UK law does not permit facilitating ("grease") payments,

-it applies to private bribery as well as the bribery of foreign officials,

-it imposes strict liability – unless you can show that you have adequate policies and procedures in place that are designed to prevent the bribe.

Please see full article below for more information.

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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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