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Global Corruption Enforcement

By Kirk Ogrosky and Jeffrey Hessekiel
January 31, 2014

For multinational corporations, reducing the risks and concomitant expenses associated with corrupt employee behavior must be a priority. In today's environment, counsel, directors and management must recognize that companies can no longer rely on the mere existence of a compliance program and code of conduct. This article discusses the benefits of embedding compliance doctrine within operations, and how businesses could market integrity and compliance to gain a competitive advantage.

Expansion into markets with challenging regulatory systems poses added risks to companies subject to the Foreign Corrupt Practices Act (FCPA), 15 U.S.C. ” 78dd-1, et. seq. Whether driven through acquisition or organic growth, expansion demands extra attention and expertise by specialized counsel. In 2014, companies should prepare for enhanced U.S. and German enforcement efforts. Mere identification of issues after expansion, however, will be insufficient to minimize risk and deal with enforcement.

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