How to Conduct Anti-Corruption Risk Assessments that Comply With the FCPA and the U.K. Bribery Act

At a time when the Trump administration seems to have affirmed its commitment to FCPA enforcement in the DOJ’s new FCPA Corporate Enforcement Policy, and with a U.K. Bribery Act that extends to areas that even the FCPA does not (including commercial bribery, domestic as well as foreign transgressions and facilitation payments), companies subject to both statutes must make sure that their anti-corruption risk assessments will pass muster in both jurisdictions. In a recent discussion during a Strafford panel, Nossaman partner Edward Fishman and John Wood, a partner at Hughes Hubbard, shared the details of how to conduct risk assessments that are both reasonably designed and meaningful. See also “DOJ’s FCPA Corporate Enforcement Policy: What’s New and What’s Not (Part One of Two)” (Jan. 10, 2018).

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