Foreign Corrupt Practices Act Internal Investigations and Enforcement Proceedings

Summary

The U.S. Foreign Corrupt Practices Act of 1977 (FCPA), 15 U.S.C. § 78dd-1 et seq., is part of U.S. federal law that prohibits corrupt payments to or for foreign public officials. Its UK equivalent is the Bribery Act 2010 (Bribery Act) as well as preceding UK legislation dealing with bribery and corruption, though there are important differences between the two laws. This practice note considers the key issues that arise during investigations and enforcement for breaches of the FCPA and provides practical insight for attorneys dealing with U.S. enforcement authorities. International cooperation and coordination between the U.S. and the UK are also discussed.