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Over the past few years, an extraordinary number of technology companies have gone public or filed paperwork to become public companies. Often times, many of these companies have experienced remarkable growth in their businesses. In the rush to “go public,” however, many of these companies pay little attention to implementing robust anti-corruption compliance programs tailored to the company’s business risks internationally.

Instead, companies dedicate resources to readying the business and implementing basic corporate governance standards using “off-the-shelf” policies and procedures sufficient to satisfy requirements imposed by the securities laws and underwriters. While that approach reflects a level of pragmatism often necessary for companies still building out their legal and compliance infrastructures, technology companies that do not revisit their Foreign Corrupt Practices Act (FCPA) compliance program within a reasonable period of time following IPO run significant compliance risks.

As evidenced by an uptick in FCPA settlements with companies in the sector—including Microsoft and Juniper Networks—many technology companies have significant FCPA risks by virtue of their international footprint, reliance on third-party resellers, and client bases which may include government agencies or state-owned or state-controlled entities. Below we set forth the top three mistakes made by newly public technology companies when it comes to FCPA compliance.

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