Anti-corruption is now a global concern. Thirty-five years after the United States enacted the Foreign Corrupt Practices Act (FCPA), countries around the world are finally establishing tough anti-bribery laws, including some that appear stricter than the FCPA itself. Although these myriad laws feature many similarities, there are important differences that must be understood, because noncompliance can lead to significant, and potentially crippling, penalties.
Importantly, financial institutions, including bank, hedge funds, and private equity funds, are not immune from these laws. Indeed, recent events suggest that regulators across the globe are increasingly focused on financial institutions’ compliance with these anti-corruption requirements, but also develop and implement effective anti-corruption policies and procedures to address this new global regime.