FCPA’s Ever-Expanding Reach Goes Private
Client Alert | 1 min read | 12.19.07
As U.S. regulators continue to explore new, more aggressive ways to prosecute foreign bribery under the Foreign Corrupt Practices Act, the Department of Justice has sent a clear warning that prosecution is not reserved for publicly traded companies on U.S. exchanges or their executives.
The DOJ announced yesterday that it had arrested a Los Angeles film executive and his wife on a criminal complaint. DOJ alleges that the couple paid more than $1.7 million in bribes to a Thai tourism official to obtain contracts worth approximately $10 million for their private company to run an international film festival in Bangkok. The complaint further alleges that the couple attempted to conceal the bribes by using multiple business entities and making “commission” payments through intermediaries and foreign bank accounts.
While the vast majority of FCPA individual prosecutions have focused on executives at publicly traded companies, by charging this case, the DOJ has reiterated that private individuals and companies are also within the crosshairs of FCPA enforcement.
Insights
Client Alert | 2 min read | 03.31.25
Canadian CMMC? Canada Proposes Cyber Compliance Regime for Canadian Defense Suppliers
On March 12, 2025, the Government of Canada announced plans to launch the Canadian Program for Cyber Security Certification (CPCSC). CPCSC is a cybersecurity compliance verification program that aims to protect sensitive unclassified government information handled by Canadian government contractors and subcontractors within Canada’s defense sector. Canada will roll out CPCSC to contractors in four phases, with the first phase launching this month.
Client Alert | 5 min read | 03.28.25
Client Alert | 10 min read | 03.27.25
FinCEN Axes Corporate Transparency Act’s Reporting Obligations for U.S. Companies and U.S. Persons
Client Alert | 3 min read | 03.27.25
