Foreign Corrupt Practices Act (FCPA)

International trade confronts companies with a minefield of anti-corruption compliance risks related to a growing list of U.S. and foreign statutes. We advise entities that do business internationally on Foreign Corrupt Practices Act (FCPA) compliance and defend clients against FCPA enforcement actions initiated by the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC), should they arise.

Fox attorneys focus on prevention, drawing from a deep well of experience to help clients design internal controls that manage FCPA compliance risk and conduct internal investigations to ferret out and address potential illegal conduct. We also help companies evaluate FCPA-related risk inherent in business transactions such as mergers and acquisitions.

In the event of an enforcement action, Fox attorneys have the experience and relationships to see a case from all angles and mount an effective defense that goes beyond standard approaches.

Download our e-book Business in a Global Society: A Guide to Understanding the Foreign Corrupt Practices Act for details on the FCPA.

Representative Work

  • Conducted an internal investigation on behalf of a publicly traded airplane parts company regarding propriety of payments to Indian Selling Agent. Provided a report to the audit committee, and no governmental action was taken as a result.
  • Defended a former CEO of Petro Tiger Company against FCPA criminal charges.
  • Designed, drafted and implemented complete corporate compliance program and in-house training presentations for a multinational food corporation.
  • Conducted an internal investigation on behalf of a publicly traded logistics company regarding travel and entertainment benefits provided to Egyptian Department of Defense employees. Provided a report to the audit committee and board, and no violations were found as a result.
  • Designed, drafted and implemented complete corporate compliance program and in-house training presentations for a publicly traded technology company.
  • Represented a privately held oil pump manufacturer in a due diligence matter in connection with the acquisition of a smaller company. Conducted an investigation, reviewed policies and procedures and provided advice on acquiring the company.
  • Designing FCPA compliance programs for an international food distribution company and publicly traded technical services corporation, among others.