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View from Wiley Rein: Is It Possible to Comply with the FCPA’s Internal Controls Provision?
With over a decade of robust enforcement resulting in billions of dollars of fines and penalties, the U.S. Foreign Corrupt Practices Act (FCPA or the Act) represents the paramount compliance challenge for companies operating internationally. The potential exposure is particularly acute for U.S. government contractors, which often have significant commercial interactions with foreign (i.e., non-United States) officials and/or the need to obtain foreign government licenses and other approvals. It is no coincidence that U.S. government contractors are the frequent targets of FCPA investigations and enforcement actions. Click here to read the full article.
(Reproduced with permission from Federal Contracts Report, 103 FCR 79, 01/27/2015. Copyright © 2015 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com.)