Eight of the top ten fines ever issued under the Foreign Corrupt Practices Act (FCPA) were levied on European companies. How can non-US companies be prosecuted under US anti-corruption laws?
All companies using US bank accounts are subject to US anti-corruption laws. A transaction involving payment in US dollars is enough to give rise to the jurisdiction of US enforcement authorities. The recent global bribery resolution between the US Securities and Exchange Commission (SEC), the US Department of Justice (DOJ), Dutch authorities and Swedish firm, Telia Company AB underscores the US Government’s continued commitment to robust white-collar crime enforcement, a commitment which extends beyond the geographical boundaries of the US.
‘Enforcement 40’ for 2020
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