FCPA Cases in Asia Continue to Focus on Non-Asia-Based Companies

New bribery methods, old problems resurfacing and continuing failures to follow up were hallmarks of 2023’s FCPA violations in Asia. But the biggest risk of anti-corruption enforcement, from the point of view of a company subject to U.S. jurisdiction, is ignoring the red flags inherent in local business practices adopted without sufficient understanding and due diligence. Such insights were shared by Steptoe partner Wendy Wysong during a recent year-in-review presentation hosted by TRACE. This article distills some of her comments. See “Compliance for M&A and Third-Party Risks in Asia” (Oct. 25, 2023).

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