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Imagine your company, a multinational corporation with operations around the world, uncovers a kickback scheme at one of its locations in which high-level managers are receiving personal payments from your company’s suppliers in exchange for ensuring those suppliers get your company’s business. As you weigh your company’s options, you are surprised to learn that the kickback scheme is not illegal under the country’s domestic laws. In fact, you may actually be violating domestic labor, privacy and contract laws if you attempt to discipline the managers or terminate the supplier relationships. Nevertheless, you are also potentially in violation of extraterritorial laws against commercial bribery like the U.K. Bribery Act and the books and records provision of the United States Foreign Corrupt Practices Act (FCPA).