The United States is stepping up its enforcement of the Foreign
Corrupt Practices Act of 1977 (FCPA), and violations of the act
carry steep fines and other penalties. Companies can reduce the
likelihood of facing such penalties with an effective
anticorruption program. Establishing this preventive measure and
interpreting the facilitation payment exclusion were hot topics at
the American Conference Institute's 21st National Conference on
the FCPA in March in New York.
Anticorruption programs undoubtedly will be put to the test by
the U.S. Department of Justice (DOJ) and Securities and Exchange
Commission (SEC), both of which are looking to increase revenue
streams for the government by enforcing the FCPA. Second only to
antiterrorism investigations, FCPA investigations have become a
priority for the U.S. government, and the FBI is now a very active
participant.
