As the DOJ and SEC broaden their FCPA enforcement efforts to include target industries beyond the usual suspects – energy and defense – all businesses with overseas ties should take a hard look at their internal anti-corruption procedures.  The nearly $2 billion in FCPA fines and penalties imposed in 2010 alone teach at least one lesson: the costs of ignoring FCPA compliance or "burying our heads in the sand" are just too high. In this rapidly-developing area of law, there is no substitute for a robust anti-corruption compliance program that prepares employees to avoid conduct and situations that can drag down an entire organization.

Click here to read Sheppard Mullin partner Bethany Hengsbach’s recently published book chapter entitled, "FCPA Compliance: Issues for Public and Private Companies."  This chapter appears in the 2001 edition of the Aspatore book, Governments Contract Compliance: Leading Lawyers on Cooperating with Government Investigations, Navigating Reporting Rules, and Implementing Compliance Programs.