The alleged use of third-party intermediaries to pay bribes to foreign government officials soared from 42% of U.S. Foreign Corrupt Practices Act (FCPA) enforcement actions in 2005 to 100% in 2011, according to our analysis of U.S. Securities & Exchange Commission (SEC) and U.S. Department of Justice (DOJ) FCPA enforcement actions reported in the Sherman & Sterling LLP 2012 FCPA Digest. (See Chart 1 below).
Third Parties: The Achilles' Heel of FCPA Compliance
The alleged use of third-party intermediaries to pay bribes to foreign government officials soared from 42% of FCPA enforcement actions in 2005 to 100% in 2011. Nevertheless, some companies may not be adapting their FCPA compliance programs quickly enough.
By
Toby J.f. Bishop And John LeonardThis premium content is locked for Business Crimes Bulletin subscribers only
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