National framework

Foreign Corrupt Practices Act (FCPA)

The 1977 US anti-bribery statute with global reach — prohibits bribing foreign officials and mandates accurate books, records and internal accounting controls.

What it is

The Foreign Corrupt Practices Act (FCPA, 1977) has two pillars. The anti-bribery provisions prohibit US persons and US-issuers (including foreign issuers listed in the US) from corruptly offering or paying anything of value to a foreign official to obtain business. The accounting provisions require US-issuers to keep accurate books and records and maintain a system of internal accounting controls — the forensic backbone that makes FCPA enforcement possible.

Why a European company should care

Jurisdictional reach is broad: any use of US mail or wires, any USD transaction, any US co-conspirator, or US-listed status can pull a European entity into the FCPA. The FCPA sits next to the UK Bribery Act and the OECD Anti-Bribery Convention as the global anti-corruption triad, and corporate compliance programmes typically design to all three simultaneously.

How this matters in our work

Babieca's collusion- and kickback-pattern detection covers the kind of payment flows that FCPA enforcement actions repeatedly surface — third-party consultancy fees, agent commissions and round-tripped vendor invoices.