What are you going to do now? Employees in your production plant in China, aided by a couple of management-level employees in your home office in the US, may have bribed Chinese government officials, avoided paying Chinese taxes, and possibly engaged in a host of other regulatory and criminal violations of Chinese laws. This
seems to have occurred despite your company’s robust compliance programme, implemented as advocated by the many legal observers who, for good reason, counsel that such programmes are essential in managing risk against the increasingly enforced Foreign Corrupt Practices Act (FCPA).
The FCPA is a potent anti-corruption statute with a broad jurisdictional reach extending, under certain circumstances, even to companies largely outside the United States. Sometimes, even if your company has done all that it could do to avoid FCPA issues, misconduct still occurs. We offer here some practical first steps to take when navigating the treacherous waters your company may face.
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Anthony Pacheco is a partner and Keith Butler is a senior associate at Proskauer in Los Angeles.
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