The Risks Of FCPA Joint Venture Liability

Law360, New York ( July 25, 2012, 1:38 PM EDT) -- The rash of recent Foreign Corrupt Practices Act enforcement actions involving joint venture partnerships — such as the cases involving RAE Systems Inc., JGC Corporation, Technip SA, ENI SPA, Snamprogetti Netherlands BV, KBR Inc./Kellogg Brown & Root Inc. and Halliburton Co. — highlight the very real and potentially significant liability that a company may face because of the misconduct of a joint venture and joint venture partners. This liability arises under both the accounting provisions and the anti-bribery provisions of the FCPA, and companies whether or not they hold a majority interest in a joint venture....

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