Ten Strategies for Avoiding FCPA Liability for Foreign Political Donations

The FCPA prohibits “corruptly” giving “anything of value” to a foreign political candidate or party for the purpose of “influencing any act or decision” that a candidate or party makes in an official capacity, but determining whether campaign funds were intended to influence a political candidate can be difficult.  In an article in our last issue, we explored past FCPA enforcement actions relating to foreign campaign contributions and detailed the corruption risk surrounding such contributions.  In this article, we provide ten strategies for mitigating that risk.  See also “Ten Strategies for Avoiding FCPA Violations When Making Charitable Donations” (Jul. 11, 2012).

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