New corporate anti-corruption policies are often rolled out with dramatic, often exaggerated assessments of their significance. This is true of the Foreign Extortion Prevention Act enacted in December. It has been described as a sea change in federal anti-bribery law and a new statutory basis for multinational companies to reexamine their compliance programs.
In reality, FEPA’s substantive and jurisdictional limitations make it largely an anti-corruption nonevent.
‘Enforcement 40’ for 2020
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