International » Big FCPA Risks For Smaller Companies

Big FCPA Risks For Smaller Companies

March 4, 2015

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In an increasingly global economy, it’s a short step from being a relatively small local or regional business to being a relatively small international business that has markets thousand of miles away. Phillips Lytle partner James Kevin Wholey, writing in the Buffalo (New York) Law Journal, takes note of this development and some baggage that comes along with it: the risk of running afoul of the Foreign Corrupt Practices Act, or similar laws from international jurisdictions. He notes that among U.S. authorities there has been an explicit and conscious attempt to target small and medium-sized business that violate the FCPA, as well as an increase in the number of prosecutions of individuals as well as companies. This post lays also out the broad outline of an FCPA compliance program, as it makes the case that no company that has moved into the international arena should fail to have one.

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