Anti-Corruption and Anti-Bribery Compliance
The U.S. Foreign Corrupt Practices Act (“FCPA”) prohibits certain U.S. and foreign businesses from making corrupt payments to foreign officials to obtain or retain business.
The FCPA also requires covered companies to make and keep accurate books and records, and to maintain an adequate system of internal accounting controls, as well as prohibit individuals and businesses from knowingly falsifying books and records. The Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) share FCPA enforcement authority.
- Transactional reviews
- Engagement of foreign distributors and agents
- Designing or enhancing effective anti-corruption and anti-bribery compliance programs
- Documented policies and procedures
- Screening and engaging potential foreign distributor and agent candidates
- Internal audits and compliance assessments
- Assessment of potential liability in due diligence investigations for mergers, acquisitions and divestitures
- Assistance with on-boarding and assimilation new business units post-closing
- Customized in-house training and training of foreign distributors/agents
- Representation during all phases of enforcement actions