Foreign Corrupt Practices Act (FCPA) & Antibribery
Compliance Programs
Of course, the best course of action is for a company to ensure that it has an up-to-date, robust, risk-based antibribery/anticorruption program in place—not merely putting together a “paper compliance program” to “check the box.” The Firm has worked with a variety of companies—from a publicly-traded franchisor with a global footprint to family-owned manufacturing companies in the targeted extractive industries sector to medical devices manufacturers and distributors and healthcare software suppliers—to assess antibribery risk, assist in building adequate compliance programs, and train employees and strategic alliance partners.
Sensitive Questions
Additionally, we advise on sensitive questions relating to the FCPA and other antibribery regimes on issues of gifts and hospitality, travel, and charitable contributions, and identify and address bribery and corruption risks related to business relationships and transactions.
Due Diligence and Risk Assessments
The Firm’s clients frequently request that we perform due diligence and assess risk profiles of target companies, international commercial agents, resellers, distributors, and other prospective counterparties located around the world, including analyzing responses to questionnaires and due diligence reports from third-party providers. We often perform these services in connection with our international trade and national security risk assessments.
Mitigating Risk in Agreements
When preparing, reviewing, and negotiating international commercial agreements and terms and conditions of sale or purchase, we are ever mindful of the need to ensure FCPA/antibribery risk is mitigated.
For assistance with FCPA and antibribery matters, please contact us at [email protected]
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News & Insights
BIS Affiliates Rule Temporary Suspension
On 1 November 2025, the White House announced that, effective 10 November 2025, BIS will suspend implementation of the Affiliates Rule for one (1) year
Former CBP Fines, Penalties and Forfeitures Branch Chief Rejoins the Firm, Opens San Juan Office
Coraly Schreiber, a former US Customs and Border Protection (CBP) Fines, Penalties and Forfeitures Branch Chief, has rejoined Yormick Law as Counsel, having practiced with
BIS Publishes 50% Rule for Entity List and MEU List Affiliates
On September 29, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule implementing a 50% ownership threshold