Normally, when a violation of the Foreign Corrupt Practices Act comes to mind, it looks a lot like this: A company, due to either corrupt intent or maybe just poor compliance practices, pays off a foreign official in return for some sort of business benefit. It’s true that this is often how FCPA cases come to be, but not always.
The less-discussed side of FCPA enforcement may not involve bribery of foreign officials at all. Companies are also vulnerable to being held liable under the accounting provisions of the law if they don’t have the right controls and protections in place.
