Jeffrey A. Lehtman, Publications, William P. Barry
Memorandum: Navigating Anti-Bribery Restrictions to Win Business in the Global Marketplace
May 14, 2008
Anti-corruption and anti-bribery initiatives are the current focus of regulators around the globe. Aggressive enforcement of the United States Foreign Corrupt Practices Act ("US-FCPA") by U.S. regulators, including enforcement actions against companies based outside of the United States for conduct outside the United States, is changing how corporations around the globe do business. Increasingly, non-U.S. regulators have taken the US-FCPA and the aggressive enforcement approach in the U.S. as a model. The efforts of the signatories to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (the "OECD Convention") , the United Nations Convention Against Corruption (the "UNCAC") and the African Union Convention on Preventing and Combating Corruption (the "AU Convention") demonstrate the extent to which the global attitude toward corruption is changing.
