Noor Wadi: The Foreign Official Next Door and Other Trends in Foreign Corrupt Practices Act Enforcement


A doctor at a Chinese state-owned hospital, an administrator at a Mexican state-owned university, and an employee at a Venezuelan state-owned oil company—what do these three have in common? They have all been considered “foreign officials” under certain circumstances in Foreign Corrupt Practices Act (“FCPA” or “Act”) enforcement.

The FCPA was passed in 1977, in the wake of the Watergate Scandal. In recent years, businesses have found it increasingly tricky to comply with the FCPA because globalization has dramatically changed the marketplace. This article will help you understand the requirements and scope of the FCPA and identify trends in FCPA enforcement, so you can help your clients remain compliant and ameliorate FCPA risks.

The FCPA is primarily enforced by the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC” and together with the DOJ, the “Agencies”). The Act consists of two key provisions, commonly known as the “anti-bribery provision” and the “accounting provision.”

Excerpted from an article on the Dallas Association of Young Lawyers (DAYL) website. To read the full article, click here.

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