The Elements of an Effective Foreign Corrupt Practices Act Compliance Program

Corporations doing business overseas have a legal obligation not to make corrupt payments to foreign officials. For those companies with connections to the United States, the Foreign Corrupt Practices Act ("FCPA") imposes criminal and civil penalties that can include multimillion-dollar fines and prison terms. Likewise, legislation prohibiting foreign bribery has been or will be enacted in the 36 countries that have signed the Organisation for Economic Co-operation and Development ("OECD") Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Signatories include all member countries of the European Union, plus Australia, Brazil, Canada, Chile, Japan, Korea, Mexico, New Zealand, Turkey, and the United States.