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A Better Partnership


Apr 2012
April 25, 2012

Corporate Bribery of Foreign Officials in the News Again

The Foreign Corrupt Practices Act (FCPA) is once again making headlines, this time in connection with allegations that Wal-Mart Stores, Inc. bribed officials in order to expedite growth of its Mexican operations and halted an internal investigation into the matter when it first came to light. If the allegations are true, both the company and some of its top officials could face serious criminal and civil penalties.

In recent years, the U.S. Department of Justice has significantly stepped up FCPA enforcement against companies and individuals. The FCPA prohibits direct or indirect bribery of foreign government officials for the purpose of retaining or obtaining business. The Wal-Mart allegations highlight the importance of strict compliance with the FCPA. In addition to outright financial bribes, conduct such as paying for a trip, making charitable contributions and buying gifts to curry favor also may be scrutinized.

We’ll discuss the FCPA in detail at our May 15 Automotive Legal Summit in Grand Rapids. More information about the Summit may be obtained by e-mailing or calling Lori Tuttle Measure ( or 616.752.2492).

If you have any questions regarding your corporation’s practices as they pertain to the FCPA, please contact Craig Meurlin ( or 616.752.2448) or another member of the International Services Practice Group at Warner Norcross & Judd.

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