By Brett Johnson, Snell & Wilmer
Recently, several companies have publicly disclosed that they are internally investigated or are being investigated by United States and foreign governments related to alleged bribery of foreign officials in an effort to obtain a business advantage. The majority of the investigations have related to alleged violations of the Foreign Corrupt Practices Act (FCPA) or similar Chinese laws. The companies have included WalMart, Sands Casino, Avon and GlaxoSmithKline, among others.
Some allegations relate to orchestrated schemes. Other allegations concern the hiring of government employees’ children, lavish trips or allotting excessive funds for entertainment purposes. In other cases, even when the companies under investigation are not directly involved, the companies’ third-party agents and vendor supply chain are implicated and the companies are still held accountable.
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