Foreign Corrupt Practices Act


FH+H attorneys advise domestic and international entities on how to conduct lawful and ethical transactions in some of the most complex, emerging economies in the world.

Services + Solutions

Our FCPA team can help clients:

  • Develop sophisticated and reliable anti-corruption programs
  • Train employees, consultants, and local representatives on how to conduct business overseas without running afoul of the FCPA’s anti-bribery provisions
  • Determine whether overseas payments are unlawful and develop alternative arrangements that are FCPA-compliant
  • Draft international party questionnaires for customers, partners, consultants, vendors, subcontractors, and local representatives that are designed to reveal “red flags”
  • Conduct due diligence on investors, acquirers, sellers, and partners to detect unlawful business practices
  • Conduct internal investigations to determine whether corrupt payments have been made
  • Properly disclose to Government authorities evidence of corruption
  • Respond to inquiries by the Department of Justice’s Fraud Division and/or the Securities Exchange Commission’s Enforcement Division
  • Defend against allegations of corrupt payments and/or improper accounting practices

Experience + Capabilities

Regardless of your industry or operating environment, FH+H can help you develop effective long-term business practices that are FCPA-compliant, and implement policies and preventative measures to help ensure that overseas transactions are conducted lawfully. FH+H’s FCPA team also routinely leverages the firm’s expertise in negotiating complex transactions to design anti-corruption strategies that are both sophisticated and practical. 

  • FH+H lawyers have sat side-by-side with clients in permissive and non-permissive environments as they negotiate FCPA-compliant transactions with friendly foreign governments and commercial customers alike.
  • FH+H lawyers bring their experience in business, accounting and litigation to bear as they conduct due diligence on parties and investigate allegations of impropriety.
  • FH+H lawyers have negotiated hundreds of transactions in virtually every major industry, including the defense, security, and intelligence contracting, government consulting, technology, aircraft leasing, retail, financial services, software, agriculture, energy, healthcare and life sciences sectors.
  • FH+H lawyers are attuned to the practices of foreign cultures, having spent years abroad in civilian and military capacities.
  • FH+H has six attorneys that hold TS-SCI clearances, and three combat veterans who previously served in various overseas locations.

Successes + Clients

Note: Case results depend on a variety of unique factors, and do not guarantee or predict similar results for future cases.

  • FH+H negotiated and closed an FCPA-compliant sale of U.S. assets to an international entity, and developed and assisted in implementation of a compliance program that ensured corruption free contract performance.  
  • FH+H defended a U.S. government contractor against allegations of violations of the FCPA and other compliance laws, including conducting a comprehensive internal investigations. 
  • FH+H defended a large non-profit against allegations of corruption. 
  • FH+H successfully represented the President of the Chinese division of a large international pharmaceutical corporation in a FCPA investigation done by both the SEC and the Department of Justice. The investigation into our client was terminated by both agencies with no charges brought against the client nor liabilities owed by the client.  

To learn more about how FH+H lawyers can help keep your business FCPA-compliant, please contact one of our professionals.