FCPA Compliance for Companies Doing Business Internationally
By Dion Macbeth, California attorney
International growth can create anti-bribery and books-and-records risk through agents, distributors, joint ventures, and government-facing relationships. Compliance should be practical enough to guide decisions in real time.
Risk-based programs work better
Companies should assess geography, industry, government touchpoints, third parties, payments, gifts, charitable contributions, and acquisitions. Policies should be supported by training, approval controls, monitoring, and accurate records.
Investigations need privilege and process
When a concern surfaces, preserve records, define the scope, protect reporting channels, and coordinate legal, compliance, audit, and board roles. A rushed or undocumented response can create additional risk.
Common Questions
Further Detail
Potentially, depending on knowledge, authorization, controls, payments, and the relationship. Third-party diligence and monitoring are critical.
Preserve records, prevent retaliation, assess privilege, and obtain prompt advice on an appropriately scoped investigation.
Legal Guidance
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