FCPA’s Ever-Expanding Reach Goes Private
Client Alert | 1 min read | 12.19.07
As U.S. regulators continue to explore new, more aggressive ways to prosecute foreign bribery under the Foreign Corrupt Practices Act, the Department of Justice has sent a clear warning that prosecution is not reserved for publicly traded companies on U.S. exchanges or their executives.
The DOJ announced yesterday that it had arrested a Los Angeles film executive and his wife on a criminal complaint. DOJ alleges that the couple paid more than $1.7 million in bribes to a Thai tourism official to obtain contracts worth approximately $10 million for their private company to run an international film festival in Bangkok. The complaint further alleges that the couple attempted to conceal the bribes by using multiple business entities and making “commission” payments through intermediaries and foreign bank accounts.
While the vast majority of FCPA individual prosecutions have focused on executives at publicly traded companies, by charging this case, the DOJ has reiterated that private individuals and companies are also within the crosshairs of FCPA enforcement.
Insights
Client Alert | 3 min read | 08.08.25
On July 24, 2025, President Trump signed an Executive Order titled “Saving College Sports” (the “Order”). The White House also released an accompanying Fact Sheet regarding the Order.
Client Alert | 4 min read | 08.07.25
Client Alert | 4 min read | 08.06.25
FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers
Client Alert | 4 min read | 08.06.25
Series of Major Data Breaches Targeting the Insurance Industry