Companies who do business overseas should pay heed to the
statements made in February 2014 by Kara Brockmeyer, the Chief of
the U.S. Security and Exchange Commission's Foreign Corrupt
Practices Act unit, that companies should act prudently by
ensuring that they have robust anti-corruption compliance
programs.
In light of the prosecution and enforcement efforts in 2013 by
the SEC and the U.S. Department of Justice aimed at the oil, mining
and gas sectors -- including significant penalties paid by Parker
Drilling Company ($12 million), Total S.A. ($398 million), and
Weatherford International Limited ($153 million) – Canadian
companies in the resources sector with any connection to the U.S.,
particularly those listed on U.S. securities exchanges, should
expect that sooner or later their overseas business practices could
come under scrutiny of U.S. enforcement authorities.