EXPOSING WRONGDOERS

International Business Dealings

United States publicly traded companies are prohibited from bribing foreign public officials in order to gain a business advantage by the Foreign Corrupt Practices Act (“FCPA”). The law also makes it illegal to make false entries in the company’s books to hide a prohibited payment. There are laws around the world with similar effect, so there may be the laws of several countries involved, depending on where the bribery took place.

Businessman receiving bribe money, US dollars, in an envelope

Foreign Corrupt Practices Act

Fines and settlements under the FCPA were in excess of $2.75 billion in 2019 alone. Some examples of activities that whistleblowers have identified as potential violations of the FCPA:

Payments to third parties, especially unqualified political and project “consultants”

Exorbitant “success fees,” including percentage interests, for political advisors

Requests for payments to third parties unrelated to a supplier

Excessive entertainment and travel provided to government officials and their families

Hiring relatives of foreign officials

Providing benefits to influence management at quasi-public organizations, such as hospitals, insurance companies, pension funds, or universities

Double invoicing schemes

Verification of suppliers against regulatory and third-party sources

Vague, non-specific description for payments made in accounting entries

Unrecorded accounts or transactions

EXPOSING WRONGDOERS

International Business Dealings

Foreign Corrupt Practices Act

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