The Importance Of HR In FCPA Compliance

Federal Corrupt Practices Act prosecutions generally have one thing in common: improper employee activity. Attorneys Libby Simmons Callan and Allison Goico explain why it’s important for Human Resources to be heavily involved in an any international employer’s FCPA compliance policy, with regard to risk assessment, training and investigations, as well as hiring and firing. In particular HR needs to pay careful attention to who is getting hired for international operations, and for what reasons. It’s now clear that government officials consider employment opportunities (including unpaid internships) a “thing of value” that can trigger FCPA liability.