When considering compliance with the Foreign Corrupt Practices Act (FCPA), the activities of an employer’s human resources department are not normally the area of initial focus. Instead, the FCPA is usually associated with claims of kickbacks to shadowy government officials in far-off locales.

We have seen the collision between human resources and FCPA compliance in recent SEC and DOJ prosecutions and multi-million dollar settlements of claims alleging that major companies hired relatives and friends of foreign government officials in order to obtain or retain business or other benefits.