Smaller Businesses Must Get Ready For FCPA Whistleblowers

Law360, New York (January 9, 2015, 8:52 AM EST) -- The Foreign Corrupt Practices Act, initially passed in 1977, prohibits payments (made directly or through intermediaries) to foreign government officials to assist in obtaining or retaining business. For many years, relatively few FCPA cases were brought. Then, starting in the 1990s and accelerating in recent years, large settlements involving multi-national companies began appearing in the news. That trend continues, as evidenced by Alstom SA’s and Avon’s recent payments of $772 and $135 million, respectively.

Thus, while the government has aggressively enforced the law, that enforcement has focused on large companies. As a result, small and medium companies doing business internationally have...

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