Tag Archives: Foreign Corrupt Practices Act

Navigating the Aggressive Enforcement of International Regulations: Eight Compliance Tips for Auto Companies

Trade
We are now two years into the current presidential administration and regulators have imposed three of the ten largest Foreign Corrupt Practices Act penalties in history and the largest export controls penalty of all time. This comes alongside significant tightening of many economic sanctions regulations and ongoing strong antitrust enforcement. With the DOJ, FBI, and … Continue reading this entry

Making the FCPA “Reasonable” — Exceptions & Affirmative Defenses

So, we have covered the Foreign Corrupt Practices Act’s (“FCPA”) scope, but the FCPA anti-bribery provisions also contain certain exceptions and affirmative defenses. These exceptions and affirmative defenses attempt to carve out legitimate payments to foreign officials, so the FCPA does not unreasonably hamper international business. Be wary, however, because prosecutors narrowly interpret these exceptions … Continue reading this entry

FCPA, Export Control, and Economic Sanctions: Enforcement Trends and Compliance

On January 24, 2013, Foley attorneys Greg Husisian and Christopher Swift briefed the Original Equipment Suppliers Association (“OESA”) Legal Council on recent FCPA, Export Control, and Economic Sanctions enforcement trends. Focusing on anticorruption, munitions, dual-use technologies, and a broad spectrum of new sanctions, the presentation identified enhanced risks for multinational companies that manufacture and export … Continue reading this entry