What are you going to do now? Employees in your production plant in China, aided by a couple of management-level employees in your home office in the US, may have bribed Chinese government officials, avoided paying Chinese taxes, and possibly engaged in a host of other regulatory and criminal violations of Chinese laws. This
Partner
Proskauer
seems to have occurred despite your company’s robust compliance programme, implemented as advocated by the many legal observers who, for good reason, counsel that such programmes are essential in managing risk against the increasingly enforced Foreign Corrupt Practices Act (FCPA).
The FCPA is a potent anti-corruption statute with a broad jurisdictional reach extending, under certain circumstances, even to companies largely outside the United States. Sometimes, even if your company has done all that it could do to avoid FCPA issues, misconduct still occurs. We offer here some practical first steps to take when navigating the treacherous waters your company may face.
You must be a
subscribersubscribersubscribersubscriber
to read this content, please
subscribesubscribesubscribesubscribe
today.
For group subscribers, please click here to access.
Interested in group subscription? Please contact us.
你需要登录去解锁本文内容。欢迎注册账号。如果想阅读月刊所有文章，欢迎成为我们的订阅会员成为我们的订阅会员。
Anthony Pacheco is a partner and Keith Butler is a senior associate at Proskauer in Los Angeles.
2049 Century Park East
Los Angeles, CA 90067-3206, USA
电话 Tel: +1 310 284 5647
传真 Fax: +1 310 557 2193
www.proskauer.com
电子信箱 E-mail: apacheco@proskauer.com
