Foreign Corrupt Practices Act (FCPA)
The Foreign Corrupt Practices Act prohibits paying or offering anything of value to a foreign official to obtain or keep business. Its accounting provisions also require public companies to keep accurate books and records and maintain internal controls. Government contractors working overseas, or with foreign partners and agents, face particular exposure.
How we help
- Risk assessments and FCPA compliance policies
- Due diligence on foreign agents, distributors, joint venture partners and acquisition targets
- Contract provisions: anti-corruption representations, audit rights and termination rights
- Training for employees and management
- Internal investigations of potential violations
- Advice on voluntary disclosure and cooperation
DOJ revised its FCPA enforcement priorities in 2025, but the statute remains in force and the limitations period for many violations is five years. A violation can also trigger suspension or debarment from federal contracting. Sound compliance remains essential.
Helpful resources
To discuss an FCPA question, call 703.448.1810.
