Wednesday, March 14, 2012 11:48:31 AM
Since 1977, the anti-bribery provisions of the FCPA have applied to all U.S. persons and certain foreign issuers of securities. With the enactment of certain amendments in 1998, the anti-bribery provisions of the FCPA now also apply to foreign firms and persons who cause, directly or through agents, an act in furtherance of such a corrupt payment to take place within the territory of the United States.
The FCPA also requires companies whose securities are listed in the United States to meet its accounting provisions. See 15 U.S.C. § 78m. These accounting provisions, which were designed to operate in tandem with the anti-bribery provisions of the FCPA, require corporations covered by the provisions to (a) make and keep books and records that accurately and fairly reflect the transactions of the corporation and (b) devise and maintain an adequate system of internal accounting controls.
For more background information regarding the anti-bribery provisions of the FCPA, please refer to the "Lay Person's Guide", found here. For particular FCPA compliance questions relating to specific conduct, you should seek the advice of counsel as well as consider using the Department of Justice's FCPA Opinion Procedure, found here.
Contact us Regarding the FCPA
By Mail
Correspondence relating to the Foreign Corrupt Practices Act (FCPA) may be sent to:
U.S. Department of Justice
Criminal Division
Fraud Section
ATTN: FCPA Coordinator
Bond Building, 4th Floor
10th and Constitution Ave. NW
Washington, DC 20530-0001
By Fax
Facsimile - 202-514-7021
By E-Mail
Report a FCPA Violation via email to FCPA.Fraud@usdoj.gov
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