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Foreign-reaching enforcement of the Foreign Corrupt Practices Act’s (FCPA) prohibitions on corrupt payments to foreign officials is alive and well. The prohibitions are intended to induce the recipient to wrongfully obtain or retain business for or with, or to direct business to, any person. The language of the United Kingdom’s Bribery Act, which recently celebrated its one-year anniversary, potentially makes the cross-border reach of the new law even greater than the FCPA in certain respects. However, there have been a limited number of cases resolved thereunder and there is much uncertainty regarding exactly how far U.K. law enforcement authorities can and will reach.

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