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"Compliance Programs Under the FCPA: Ways to Minimize Liability for Payments to Foreign Officials"

For international businesses, one provision of the Foreign Corrupt Practices Act (FCPA) has become a source of great liability over the last decade ‒ the FCPA’s ban on payments to “foreign officials.” This information paper illustrates how liability can arise and offers practical strategies to minimize liability through a compliance program.

The Foreign Corrupt Practices Act (FCPA) initially had limited enforcement from its inception in 1977 until around 2002. However, over the past decade, there has been a significant increase in FCPA prosecutions, making it a top concern for international businesses. 

This paper focuses on the FCPA’s provision regarding payments to foreign officials, which has become a significant source of liability. It discusses a case involving Alcoa Inc. as a cautionary tale, where the company used a middleman to funnel bribes to Bahrain’s royal family, resulting in substantial fines and penalties. 

Download the information paper now and learn more about:

• A basic understanding of FCPA’s terms.
• 10 vital elements of an effective compliance program.
• How FCPA enforcement has evolved since its inception.
• A cautionary tale of FCPA liability.

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