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In Part I of this article, we discussed the Foreign Corrupt Practices Act (FCPA) and the resource guide that accompanies it (“the Guide”). The Guide aims to define the terms of the FCPA and help clarify what exactly is and isn’t covered by its parameters. However, as we addressed, these terms are subject to ambiguity due to the cultural and linguistic variables associated with certain concepts and phrases, which can put the parties involved on very different pages of the same book. The second part of our article will explore some of the circumstances in which these variables often have a complicating effect, as well as look at what international businesses can do to sidestep these challenges.

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