In recent years, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) have become increasingly aggressive in their enforcement of the Foreign Corrupt Practices Act (FCPA). The FCPA prohibits U.S. companies and citizens, as well as foreign companies listed on a U.S. stock exchange, from bribing foreign officials to secure improper advantages or to influence certain actions. The monetary fines and penalties imposed by the government on companies found to have violated the FCPA have escalated, resulting in multimillion-dollar corporate fines and sanctions that may include the termination of export licenses and debarment from government contracting programs. The government also has shown an increasing appetite for prosecuting individuals, both U.S. citizens and foreign nationals, for directing and authorizing payments to foreign officials.
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