Recent FCPA Cases: Lessons for Compliance Personnel

Historic Corruption and Its Modern-Day Impacts

Anne Eberhardt, CFE, CAMS and Senior Director at Gavin/Solmonese, discusses two notable cases involving corruption, bribery and consequent violations of the Foreign Corrupt Practices Act. Each offers instruction for compliance practitioners.

This autumn we are commemorating two significant anniversaries: the 10-year anniversary of the financial crisis and the centenary of the end of the First World War. Another anniversary that may have escaped widespread notice will come in November: 101 years after Leon Trotsky, in his capacity as the Bolshevik foreign minister, gleefully exposed the Sazonov-Sykes-Picot agreement, revealing Russian, British and French imperial plans to carve up the Ottoman Empire. The release of the document embarrassed the British and French governments, whose foreign ministers had made contradictory and unfulfillable promises to various tribal leaders in exchange for their help securing a military defeat against the Turks. And of course, Sykes-Picot lives in infamy, rightly or not, as the root cause of the perennial unrest of the contemporary Middle East.

Several recent Foreign Corrupt Practices Act (FCPA) cases have revealed widespread corruption involving global corporations and their affiliates located in the regions…


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