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FCPA Compliance Now Essential for All Companies That Do Business Internationally
For corporate counsel whose clients do any business internationally, the U.S. Foreign Corrupt Practices Act (“FCPA”) recently has become a pressing issue. U.S. Department of Justice (“DOJ”) officials have stated that enforcing the FCPA has become one of the DOJ's top priorities. Since mid-December, companies have paid more than $1.3 billion to settle FCPA charges. Multiple executives have also recently pleaded guilty to FCPA violations and are facing years in prison and/or millions in financial penalties.
Although the hundreds of millions of dollars in FCPA penalties assessed against huge entities like Siemens AG, Halliburton Co. and Kellogg Brown & Root LLC garner the most press, even small- and mid-sized companies with limited overseas sales are facing increased FCPA enforcement. For example, AGA Medical Corporation (“AGA”) settled charges related to alleged FCPA violations in China. During the time of the alleged violations, AGA's Chinese sales totaled an average of only about $1.5 million per year.
FCPA Requirements and What They Mean to You
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