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The Foreign Corrupt Practices Act is designed to criminalize and prevent bribery of government officials of other countries. Codified as amended at 15 U.S.C. ��78m, 78dd-1, 78 dd-2, 78ff (2000). The FCPA is drafted in very broad terms and is designed to bring all American companies and even individuals within its boundaries. As the Department of Justice Web site notes, the “FCPA potentially applies to any individual, firm, officer, director, employee, or agent of a firm and any stockholder acting on behalf of a firm.” United States Attorneys’ Manual, Title 9, Criminal Resource Manual, �1018, Prohibited Foreign Corrupt Practices (November 2000). Therefore, all American companies involved in international commerce, whether large, mid-sized or small, and whether publicly traded or not, need to take appropriate steps to comply with the FCPA.

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