▸ Chapter 4Non-Governmental Organizations Anticorruption Compliance Challenges and Risks

Elena Helmer and Stuart H. Deming

DOI: 10.4324/9781003387800-8

Originally published as Non-Governmental Organizations: Anticorruption Compliance Challenges and Risks, in The International Lawyer (2011): 597–624. Reprinted with permission.

Introduction

Over the course of the past decade, enforcement of the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA),1 prohibiting the bribery of foreign officials,2 has experienced tremendous growth.3 The growth of foreign bribery prosecutions under the FCPA has been exponential in nature4 when consideration is also given to the use of the FCPA’s accounting and record-keeping provisions as an alternative ...

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