Regulatory Note

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Does your company do business internationally? If so, then the business and legal risks of potential corruption should be top of mind. In the U.S., the Department of Justice, FBI, and the Securities and Exchange Commission have begun a rigorous anticorruption campaign, and the prosecution of non-compliant global businesses under the Foreign Corrupt Practices Act (FCPA) is on the rise.

The FCPA consists of two provisions: the anti-bribery provision and internal records and process standards. The anti-bribery provisions prohibit companies from giving money, gifts, or anything of value to obtain or retain business. The internal records and process standards require companies keep accurate records and maintain clear, accurate, and adequate controls with employees and trading partners (including suppliers, intermediaries and subsidiaries) to protect against improper payments or influence.

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