For Canadian companies, the causal link that needs to be established in order for the U.S.’s Securities Exchange Commission to enforce the [FCPA] is “minute,” Cassidy continued. “From a Canadian perspective, we need to keep our eyes on this,” he said. “There doesn’t need to be a close proximity geographically: a Canadian owned and operated company that doesn’t even have its feet in the U.S. is at risk. “If funds flow through a U.S. bank, or if your servers are hosted in the U.S., the SEC can exert its enforcement.”
Read more: Causal link for SEC to go after Canadian companies is “minute” — Canadian Underwriter