Foley Partner Lisa Noller and Associate Carmen Couden authored an article that appeared in Product Liability Law360 on March 16, 2011 titled “Growing Risk: FCPA Exposure For Foreign Food Cos.” The authors discuss new provisions in the Food Safety Modernization Act that unintentionally create foreign bribery risks for foreign importers of food. They state that international importers of food into the United States will need to incorporate U.S.-style compliance programs in order to prepare for the new provisions, adding that costly litigation can be avoided by implementing compliance measures that address potential bribery risks.
