Publications

05.09.17 | Articles

How the FCPA Applies to Private Companies

New York Law Journal

In recent years, investigations and prosecutions under the Foreign Corrupt Practices Act (FCPA) have generally involved public issuers of securities in the United States, not private companies. In this article, we address how the FCPA applies to private U.S. companies, discuss recent enforcement activity involving private companies and their employees, and suggest why private companies may receive increasing attention in the future from FCPA enforcement authorities.

How the FCPA Applies to Private Companies (PDF | 450.86 KB)