Managing FCPA Risk While Fulfilling Local Content Requirements
The Review of Securities & Commodities Regulation
In this article, James Tillen and Chervonne Colón Stevenson* discuss the U.S. Foreign Corrupt Practices Act (FCPA) challenges faced by companies operating in countries that have local content requirements. Focusing on Nigeria, Angola, and Malaysia, the authors describe the FCPA risks associated with the local requirements and provide compliance strategies companies can employ to mitigate risks. "The landscape of local content requirements can vary greatly from country to country," the authors wrote. "While the local content requirements may pose FCPA risks, with proper planning and tailoring of compliance strategies, foreign companies can successfully manage such risks."
*Former Miller & Chevalier attorney