FCPAméricas Blog
Archive for Business Purpose category:
Third-Party Due Diligence—Not Just a One Time Thing
4.11.2018
This post was authored by Leah Moushey, an Associate at Miller & Chevalier Chartered. It is no secret that a company can be held liable under the FCPA for misconduct carried out by third parties. Indeed, the majority of corporate resolutions involve the participation of agents, consultants, distributors, lawyers, accountants, or other third-party intermediaries. Under […]
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What FCPA Enforcement is Thinking in 2013
12.06.2013
What is the current thinking of FCPA enforcement officials at the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC)? At ACI’s 30th International Conference on the FCPA this year, two top officials provided insights (they clarified that their statements reflected their own views and not the views of their respective agencies). […]
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Understanding the FCPA — Where Lawyers Go for Guidance
7.31.2012
On my last trip to Latin America, attorneys asked me how they could learn more about the FCPA from primary sources. Like most of us, they regularly receive alerts and notices from law firms, accounting firms, investigation outfits, and consultants. They read the blogs, including FCPAméricas. And they see press articles (people are still talking […]
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Risky Business: The Unexpectedly Broad Application of the FCPA’s Business Purpose Element
1.24.2012
Today’s blog post is also cross-posted on the Click4Compliance Blog. Companies and individuals subject to the U.S. Foreign Corrupt Practices Act (FCPA) often misunderstand the scope of subject activity. They assume that bribes are illegal only if they relate to a company’s core business. As a result, they might focus anti-corruption compliance efforts in areas […]