Commercial Bribery: The FCPA’s Forgotten Counterpart

Many anti-corruption compliance programs are focused on preventing bribes being paid to foreign officials, but in both the U.S. and abroad there has been increasing attention paid to commercial bribery. In a guest article, Lucinda Low, Brittany Prelogar, Zoe Osborne and Jessica Piquet Megaw of Steptoe argue that corporate prohibitions on public sector bribery are insufficient to mitigate anti-corruption enforcement risks related to commercial bribery and that compliance programs should be reevaluated to fully mitigate this risk. See “$25M Microsoft Settlement Highlights Channel Partner Risk and the Value of Tech in Remediation” (Aug. 7, 2019).

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