The u. S. Foreign corrupt practices act implications for international distributors

Other aspects of FCPA affect foreign businesses involved with US

• Other aspects of FCPA affect foreign businesses involved with US
• ▪ Actions of contractual parties imputed to the principal: includes U.S. agents, distributors, consultants, contractors, subsidiaries, etc.
• - US-based agent with “North American” territory may violate FCPA bribery rules in Mexico
• - US-based agent may seek reimbursement of mischaracterized expenses, violate accounting rules
• ▪ Increasing international cooperation on corruption issues
• - KBR: US, France, Italy, Switzerland, UK
• - Siemens: Germany, US, Italy, China, Hungary, Indonesia, Norway
• ▪ Expect ‘trickle-down’ of FCPA requirements from affected companies

• More Implications of the FCPA