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Foreign Corrupt Practices Act: A Practical Resource for Managers and Executives


Companies don't pay bribes. People do.Train your people. Protect your company.

"Aaron Murphy has written the best practical guide to avoiding FCPA perils in print today. He hits all the buttons—including the ones you didn't know exist. So you've endured the usual PowerPoint presentations? Convinced that you have what you need to sidestep overseas bribery? Get ready for a surprise."
Tom Donaldson , Mark O. Winkelman Professor, Wharton School of the University of Pennsylvania

"Aaron Murphy has written a marvelous book on the increasingly complex and difficult challenges posed by the Foreign Corrupt Practices Act (FCPA) . . . What I love most about Aaron's book, however, is its emphasis on culture, leadership, and process in addressing FCPA risk . . . It will be helpful to specialists, and even more so to business leaders and managers, in doing what the overwhelming majority of those leaders and managers strive to do—lead with integrity."
Brackett Denniston, Senior Vice President and General Counsel, General Electric Company

AARON G. MURPHY is a partner in the international law firm of Latham & Watkins. He has advised on FCPA matters on five continents and has conducted in-country bribery investigations in more than a dozen countries in Asia, Africa, the Middle East, Central Asia, and Europe. His clients include Fortune 100 companies, small- and mid-sized companies both public and private, as well as individuals.


Introduction Who Is This Book For?

CHAPTER 1 Basics of the Foreign Corrupt Practices Act.

CHAPTER 2 What's the Big Deal? Billion-Dollar Fines and Jail Time.

CHAPTER 3 You Do More with the Government Than You Think.

CHAPTER 4 Know Your Customers and Suppliers: The Dangers of State-Owned Entities.

CHAPTER 5 Guess Who's Coming to Dinner? The Dangers of Meals and Entertainment.

CHAPTER 6 Ensuring that Business Trips Really Are For Business.

CHAPTER 7 Gifts that Give Back.

CHAPTER 8 Know Your Agents and Consultants.

CHAPTER 9 So What Can You Do? Facilitating Payments and Other Exceptions.

CHAPTER 10 Keeping Good Records and Maintaining Good Procedures.

CHAPTER 11 Are You Buying a Problem? Due Diligence in Acquisitions and Government Contracts.

CHAPTER 12 Time Off for Good Behavior: Why Compliance Matters.

APPENDIX 1 Anti-Bribery, Record-Keeping, and Internal Controls Provisions of the Foreign Corrupt Practices Act.

APPENDIX 2 Relevant Provisions of the Principles of Federal Prosecution of Business Organizations.

APPENDIX 3 Excerpts from the Federal Sentencing Guidelines Manual.

About the Author.