ARTICLE · 18 NOVEMBER 2022

The Foreign Corrupt Practices Act – An Executive Summary

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Recent months have seen a resurgence in interest in the Foreign Corrupt Practice Act (FCPA) and related matters as a result of enforcement activity that have yielded significant fines...

United StatesGovernment, Public Sector

The Foreign Corrupt Practices Act

An Executive Summary

Recent months have seen a resurgence in interest in the Foreign Corrupt Practice Act (FCPA) and related matters as a result of enforcement activity that have yielded significant fines, penalties, and disgorgements. In one instance, a company had to pay a $700 million settlement to resolve FCPA claims brought against it (not to mention additional fines in other countries).

So far in 2022, FCPA enforcement authorities have targeted businesses involved with a variety of industries, including natural resources, financial services, waste management, healthcare, steel manufacturing, aviation, insurance, and technology. In some cases, these companies were headquartered outside the United States – a clear reminder of the extra-territorial jurisdiction that U.S. authorities continue to assert when pursuing FCPA cases.

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