Deemed Public Officials: A Potential Risk for US Companies in Japan

Latham & Watkins LLP

Japan is one of the lower-risk countries for US companies in terms of compliance issues involving bribery and corruption.

Transparency International’s 2013 Corruption Perceptions Index places Japan 18th out of 177 countries, on a par with the United States (19). This is a much higher position than other Asian countries, including South Korea (46) and China (80). However, in addition to considering potential exposure to the United States’ Foreign Corrupt Practices Act and the United Kingdom’s Bribery Act 2010, there are a number of unique local issues of which US companies should be aware.

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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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