The Future of Anti-Corruption Enforcement

In this interview, Homer Moyer discusses the UK Bribery Act (the Act) just before its release. He discusses the impact generated by the Act’s enforcement on businesses as well as its possible influence on the strength of anti-corruption enforcement performed by the U.S. Department of Justice under the Foreign Corrupt Practices Act (FCPA). As a result of the Act’s implementation, Mr. Moyer predicts an increase in coordinated enforcement efforts between the U.K. and the U.S., continued prosecutions under FCPA for bribery claims taking place outside of the U.S. for non-U.S. companies, and rising number of companies that will need to be aware of the Act’s provisions and create anti-corruption compliance programs as a result of the Act’s increased jurisdictional reach, among others.
When asked about advice to offer companies that are developing or improving upon current anti-corruption programs in order to meet requirements of both the FCPA and UK Bribery Act, Mr. Moyer recommends “to have in place a good, thoughtful, risk-based compliance program. If a company has a strong compliance program that meets the ever-moving target of best practices under the FCPA, it should be well-positioned. Companies may well want to tweak their programs to meet new UK standards.”
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The Future of Anti-Corruption Enforcement
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