Troutman Pepper Locke’s Guide to Anti-Corruption Compliance

Bribery and corruption are illegal. What does that mean in practice? Various countries have enacted laws to combat corruption, including India's Prevention of Corruption Act, the UK Bribery Act of 2010, and the Canadian Corruption of Foreign Public Officials Act. In the U.S., the Foreign Corrupt Practices Act (FCPA) remains a critical and often challenging compliance requirement for U.S. and many non-U.S. companies that do business abroad. In 2025, the Trump administration issued an executive order and subsequent updated guidelines that changed the U.S. Department of Justice's (DOJ) historical approach to FCPA enforcement, creating uncertainty for how companies should consider FCPA risk.

Troutman Pepper Locke's White Collar Litigation + Investigations team has prepared a concise guide addressing critical questions, including:

· Bribery and Corruption Are Illegal — What Does That Mean? Learn about the FCPA's anti-bribery and accounting provisions, who they apply to, common theories of liability, current enforcement priorities, and the statute of limitations.

· Your Company Does Business Abroad — What Do You Need to Think About? Conducting risk assessments, designing anti-bribery policies, vetting third-party business partners, training employees, maintaining accurate records, establishing confidential reporting structures, and fostering a culture of compliance.

• You Have Concerns That There Might Be a Violation — What Do You Do? How to conduct internal investigations, when to consider disclosure obligations to auditors and regulators, and whether to self-disclose to the SEC or DOJ to receive potential declinations of prosecution.