Small and mid-cap companies operating internationally are having to readdress their corruption compliance programmes following a record number of Foreign Corrupt Practices Act (FCPA) enforcement actions last year, and a shift away from the Act’s traditional focus on large companies.
In the past they’ve been able to escape the FCPA’s focus, said Arnold & Porter partner Marcus Asner, but they now face increased scrutiny.
“Some of the smaller companies haven’t yet gone through the experience of an FCPA enforcement action. They may be operating in high risk areas but may not yet have an up-to-date,...