Which Individuals Within a Company Face the Greatest Risk of FCPA Prosecution?

Over the past several years, there has been an uptick in prosecutions of individuals – as opposed to companies – for FCPA violations.  Employees, agents and board members of multi-national corporations who interact with foreign officials, supervise others who interact with foreign officials or exercise control over a company’s finances are all at risk of violating the FCPA.  During a recent program, FCPA experts addressed which individuals are most at risk, which specific activities put these individuals at risk and how companies can mitigate these risks.  See also “Anti-Corruption Compliance Best Practices for Boards of Directors,” The FCPA Report, Vol. 2, No. 12 (Jun. 12, 2013).

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