Financial Turmoil and the Expanding Reach of the FCPA

The current worldwide financial crisis may lead to unexpected results for U.S. businesses and individuals in their efforts to comply with the Foreign Corrupt Practices Act (FCPA). As foreign governments bail out, and in some instances nationalize, commercial and investment banks, employees of those previously private financial institutions may become “foreign officials” for purposes of the FCPA. Thus, companies must determine whether their dealings with those institutions now implicate the FCPA.

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