It is no longer safe for companies to rely exclusively on their FCPA compliance programs as a means for staying compliant with their foreign bribery obligations throughout the world. Countries have committed themselves to combating foreign bribery through international treaty obligations and newer foreign bribery laws, such as the UK Bribery Act, that have imposed tougher anti-bribery standards on companies operating on an international basis. International enforcement of these foreign bribery laws has also peaked in aggressiveness.
Companies need to tailor their FCPA compliance programs to adapt their programs to the current international anti-bribery environment. They need to look at current international guidance on anti-bribery compliance programs and make their compliance programs truly international foreign bribery compliance programs that can better protect them in a world increasingly hostile to foreign bribery.
This article will explain the major laws and international treaties governing foreign bribery and the need for effective compliance procedures in an international anti-bribery environment. This article will also explore some of the guidance provided by domestic and international authorities on procedures that should be included in an effective international foreign bribery compliance program. Finally, this article will provide a list of minimum compliance procedures, covering A to Z, which should be incorporated in any comprehensive international foreign bribery compliance program.
The Need for a Comprehensive International Foreign Bribery Compliance Program, Covering A to Z, in an Expanding Global Anti-Bribery Environment,
Dick. L. Rev.
Available at: https://ideas.dickinsonlaw.psu.edu/dlra/vol117/iss1/4