Laws that may apply
Companies with a U.S. connection often focus on the Foreign Corrupt Practices Act, which reaches payments to foreign officials and also imposes recordkeeping duties on companies whose securities trade in the United States. Federal FCPA enforcement priorities were narrowed in 2025, yet the statute remains in force, charges can still come after a policy shift, and foreign governments enforce their own anti-bribery laws, some reaching private-sector bribery. Domestic rules matter as well: federal law addresses bribery involving government programs, and New York criminalizes commercial bribery between private parties. A compliance program has to account for the laws that actually touch your business, not just the most familiar one. Getting that map right is the starting point.
Controls that hold up in practice
Much bribery risk comes through third parties such as agents, distributors, consultants, and joint venture partners who deal with officials on your behalf. Vetting those parties before engagement and paying them through transparent channels are common safeguards, and contracts often carry anti-bribery commitments. Gifts, travel, and hospitality policies should be clear enough for employees to apply without guessing. Books and records should describe payments accurately, because vague entries are often what investigators notice first. A channel for employees to raise concerns, and a record of how those concerns were handled, completes the picture.
Getting started or catching up
We help companies assess where their exposure lies, write or update policies, and plan diligence on third parties and acquisitions. A first conversation usually covers where you operate, who you sell to, which intermediaries you rely on, and what controls exist today. If a concern has already surfaced, the discussion shifts to whether an internal review is needed and how to handle it carefully. Programs should be proportionate to the business, and a smaller company does not need the same structure as a multinational. What matters is that the program reflects real risk and is actually followed.
