Category Archives: FCPA

Subscribe to FCPA RSS Feed

Beyond the Checklist: Seven Keys to Effective Trade Due Diligence

Anti-corruption due diligence can be vexing even in the best of conditions; it is often made more complicated by time and business pressures that arise in the context of a merger or acquisition or an urgent sales opportunity.  Anti-corruption compliance is always fact-intensive, and due diligence is no exception, requiring many judgment calls about what … Continue Reading

Doing Business In Latin America: Does Your Local Supplier Have Best Practices In Place So That Your Company Can Avoid Liability Under The FCPA?

Imagine yourself the CEO of a successful multinational company. In the past few years, you have overseen ACME’s expansion into Latin America – a market whose demographic profile holds the promise of mouthwatering profits for your company, particularly with the upcoming holiday season. As they say, la vida es buena!… Continue Reading

Line in the Sand: Siemens Argentina Case Limits Personal Jurisdiction Under the FCPA

By Thad McBride and Cheryl Palmeri A New York federal district court judge has dismissed a Foreign Corrupt Practices Act (“FCPA”) claim against a former executive of Siemens, S.A. Argentina and Siemens Transportation Systems for lack of personal jurisdiction. The U.S. Securities and Exchange Commission (“SEC”) brought the civil FCPA enforcement action against Herbert Steffen … Continue Reading

Meaning Of FCPA’s “Foreign Official” Causes Uncertainty For Companies Doing Business Abroad

By Alison N. Kleaver and Joseph Barton One of the goals of the Foreign Corrupt Practices Act (“FCPA”) is to prevent US companies and individuals from paying bribes to foreign officials in exchange for business. To this end, the FCPA prohibits any domestic individual or business entity from making payments to a “foreign official” for … Continue Reading

Increased Opportunities for Foreign Investment in Brazil Also Bring Increased Risk for FCPA Violations

By Curt Dombek and Karin Johnson With the award to Rio de Janeiro of two of the highest profile sports events in the world—the 2014 World Cup and the 2016 Summer Olympics—many U.S. and multinational corporations will be looking for investment opportunities in Brazil. If the 2008 Olympics in China are to be any kind of … Continue Reading
LexBlog