FCPA Violations By 3rd Parties: What To Watch For

Law360, New York ( May 6, 2016, 2:00 PM EDT) -- U.S. companies and others subject to jurisdiction under the Foreign Corrupt Practices Act can be held vicariously liable for an FCPA violation committed on their behalf or at their direction by third parties. In fact, most enforcement actions brought by the U.S. Department of Justice and the U.S. Securities and Exchange Commission under the FCPA involve third parties. International consultants, sales representatives and distributors represent a huge danger area for defense contractors (and other companies) seeking to grow their international business in high-risk countries around the world....

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