James Koukios spoke to Anti-Corruption Report about the new Foreign Corrupt Practices Act (FCPA) enforcement guidelines, including the memo’s directives to protect U.S. companies by prioritizing prosecution of conduct that most undermines the economic interests of U.S. companies.
James stated, “Deciding whether to bring an FCPA enforcement action based on whether an American business was impacted is a very significant change in the way that FCPA prosecutors evaluate cases.” He noted that American companies could still fit within the scope of these directives, adding that “it is quite possible that a bribe paid by one American company could harm another American company.”
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