By Susan Osborn, Director Advisory Services, Americas
There are several ways a person can be considered a foreign official according to FCPA. Outside of those clearly employed by the government or government agencies, several others fall under the foreign official heading.
Last week’s webinar Foreign Corrupt Practices Act: Your Company’s Future on the Line, encouraged a lot of discussion and resulted in several interesting questions from attendees for presenter and FCPA expert Roy McDonald. Here are some of the highlights, as well as Roy’s answers:
Q. How far down the chain does third party liability go? What about second- and third-tier business intermediaries who may work directly for the third party?
Did you know that in 2010 more than $1.5 billion in penalties were levied against companies for Foreign Corrupt Practices Act (FCPA) violations? With fines on the rise and some high profile organizations being accused of breaking this law, it’s important that companies with operations overseas or planning to expand internationally understand the implications.