Och-Ziff, one of the world's largest hedge funds, is being investigated for FCPA violations related to activities in Africa. The investigation is evidence that US authorities are increasingly intent on holding individuals accountable for corporate fraud. It's also a strong reminder to US companies of the risks involved when engaging intermediaries to facilitate business transactions abroad.
It is a well-worn cliché that people are a company’s greatest asset. The trick is investing resources and time to demonstrate that, to develop talent and to make it feel valued. By visiting your teams overseas and listening to their concerns and ideas, you demonstrate that you value their contributions and are committed to their success.
Is anyone you are working with considered a "foreign official"? Make sure you are operating in full compliance.
As with many aspects of international expansion, it’s not always cut and dry, with confusion around what falls under the act’s jurisdiction.