Death Of Trump Corruption Enforcement Greatly Exaggerated

Enforcement of laws governing companies’ international operations is alive and well, according to this client alert from Foley & Lardner. Laws in question include the Foreign Corrupt Practices Act, various anti-money laundering laws, as well as laws governing economic sanctions, exports, and the arms trade. Two high-profile enforcement actions are cited to demonstrate that “any thought that the Trump administration might take a more lenient approach toward these international regulations has been laid to rest.” In the Panasonic case, the company agreed to pay $280 million to resolve FCPA offenses involving an alleged scheme that involved paying a Middle Eastern government official nearly a million dollars for “purported consulting” in exchange for help in gaining a lucrative contract from a state-owned airline. The second case targeted a Chinese telecom equipment company for trading with Iran, in violation of U.S. sanctions. The penalty, in this case, was more than a billion dollars, with $300 million suspended during a seven-year probationary period. This article concludes with a suggested “twelve-step program” to help companies identify and mitigate the risk of running afoul of these laws.