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The Foreign Corrupt Practices Act

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DEMING PLLC, with offices in Washington, D.C. and Michigan, is one of the leading law firms specializing in the full range of issues relating to the Foreign Corrupt Practice Act (FCPA). DEMING PLLC has extensive experience on issues relating to international law and works with companies, organizations, audit committees, and individuals, and their law firms, to provide advice and assistance relative to complying with the FCPA, including developing compliance programs and adequate internal controls, undertaking FCPA compliance audits, addressing Sarbanes-Oxley issues, conducting internal investigations, and representing clients in U.S. Department of Justice and U.S. Securities and Exchange Commission investigations.

The FCPA’s Anti-Bribery Provisions

InternationalPractitionersDeskbookSeriesWhile the purpose and language of the anti-bribery provisions of the FCPA appear to be straightforward in nature, the statute is much more nuanced than is generally recognized. Its scope and means of application can be complex and can lead to dramatically unexpected results. Without a thorough knowledge of the FCPA, serious misunderstandings can and often do occur. DEMING PLLC has the depth of experience and requisite knowledge to provide sound and reliable advice concerning the anti-bribery provisions of the FCPA.

The FCPA’s Internal Controls and Record-Keeping Provisions

Often overlooked in the dramatic increase in enforcement of the FCPA is the critical role of its accounting and record-keeping provisions.  In addition to prohibiting improper inducements to foreign officials, the FCPA placed new and significant obligations on issuers to maintain records that accurately reflect transactions and dispositions of assets and to maintain adequate systems of internal accounting controls.

The accounting and record-keeping provisions apply to all aspects of an issuer’s practices relating to the preparation of its financial statements and extend to their worldwide operations. Compared to the anti-bribery provisions, in many respects, the accounting and record-keeping provisions constitute the more potent mechanism.  No proof of intent is required to establish a civil violation.  A criminal violation can lead to a 20-year term of imprisonment as opposed to a five-year term under the anti-bribery provisions.

While DEMING PLLC has extensive experience handling all aspects of the FCPA, it has particular expertise related to the internal controls and record-keeping provisions. This expertise extends to issues associated with maintaining accurate books and records, designing and implementing adequate internal controls, and meeting the requirements of Sarbanes-Oxley.  In this regard, DEMING PLLC assists companies, organizations, audit committees, law firms, and auditors in providing advice, developing polices and procedures, and assisting with internal investigations.


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