Just past its 30th birthday, the Foreign Corrupt Practices Act of 1977 today poses the greatest liability risks ever for U.S. firms and other covered entities pursuing business opportunities abroad. This increased risk arises due to the increased chance of prosecution by the U.S. government, the government’s increased appetite for large fines, and the increased risk of multiple prosecutions due to other countries having adopted FCPA-equivalent laws, as perhaps best symbolized by Siemens being forced to pay $1.6 billion in fines to anti-corruption authorities in Europe and the United States.
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