Bags of cash.  Luxury vehicles.  Exotic travel.  When we think of foreign bribery, and the prosecutions under the Foreign Corrupt Practices Act that attempt to control it, this is what comes to mind.  But how does a U.S. enforcement agency ferret out evidence of these quintessential bribes when they take place across the world, buried in a web of subsidiaries and subcontractors, especially with a global pandemic curtailing investigative resources and abilities?

The answer is within the FCPA itself, as recent enforcement actions have highlighted.  The best-known sections of the law concern these overt value transfers to government officials in exchange for a permit, construction green light, or other government benefit.  But there are other, long less used, parts of the FCPA that bolster the government’s ability to control illegal payments.  They are now getting the spotlight, thanks to some recent SEC and DOJ enforcement actions.

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