In our expanding global economy, companies increasingly conduct business internationally. As a result, in-house counsel must be more aware than ever of anti-corruption laws both in the U.S. and abroad.
In the United States, the key anti-corruption statute is the Foreign Corrupt Practices Act (FCPA). Only moderately enforced until the 2000s, FCPA “enforcement actions” have generally increased through 2010 with a slight leveling off in 2011 and 2012. Nonetheless, the statute continues to garner significant attention because of the severe penalties, sparse legal guidance and expansive interpretation of the Act.