Twenty-five years after its initial passage, the Foreign Corrupt Practices Act (FCPA)[1] remains a viable deterrent to international bribery by United States companies.

However, while the statute carries stiff penalties for bribery of foreign officials and has spawned numerous corporate compliance programs designed to eliminate such graft, international bribery still appears to be prevalent. While the FCPA has had some impact in policing American companies, international competition and the willingness of foreign officials to cast a blind eye toward corruption, particularly in developing countries, has, in the view of many businessmen, placed American companies at a competitive disadvantage and cost them business.