Compliance Programs Under the FCPA: Ways to Minimize Liability for Payments to Foreign Officials

The Foreign Corrupt Practices Act (FCPA) initially had limited enforcement from its inception in 1977 until around 2002. However, over the past decade, there has been a significant increase in FCPA prosecutions, making it a top concern for international businesses. 

This paper focuses on the FCPA’s provision regarding payments to foreign officials, which has become a significant source of liability. It discusses a case involving Alcoa Inc. as a cautionary tale, where the company used a middleman to funnel bribes to Bahrain’s royal family, resulting in substantial fines and penalties. 

Download the information paper now and learn more about:

  • A basic understanding of FCPA’s terms.
  • 10 vital elements of an effective compliance program.
  • How FCPA enforcement has evolved since its inception.
  • A cautionary tale of FCPA liability.


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