Anti-Corruption Law and Compliance: Guide to the FCPA and Beyond, with 2018 Cumulative Supplement

An invaluable resource for legal and compliance professionals at law firms or multinational corporations, this unique treatise reviews the context of anti-corruption and anti-bribery laws, agreements, and penalties. The work outlines strategies, best practices and essential elements of effective anti-corruption compliance programs. The treatise also looks at international anti-corruption agreements and enforcements, as well as laws in different industries, namely, oil and gas, defense, pharmaceutical, and foreign infrastructure.



Anti-Corruption Law and Compliance reviews the origins, meaning, and applications of the U.S. Foreign Corrupt Practices Act (FCPA), in addition to coverage of the countries of China, the U.K., France, and Brazil, as ever-increasing enforcement by other countries continues to create considerable challenges for businesses facing allegations, investigations, or prosecutions in multiple jurisdictions. The prosecution of individuals as well as corporations also make this book’s detailed review of the FCPA’s specific provisions essential reading for attorneys representing individuals or businesses facing investigation or prosecution.

Specific chapters cover: key concepts such as jurisdiction, elements, enforcement, defenses, accounting provisions, penalties, and collateral consequences; particular areas of business such as oil and gas, defense, and the pharmaceutical, medical device, and healthcare-related industry; and the World Bank and other international financial institutions.

The 2018 Cumulative Supplement includes:


  • United Kingdom enforcement, including the continued use of Deferred Prosecution Agreements in the U.K., and the first-ever conviction against a defendant who sought to make an adequate procedures defense under the U.K. Bribery Act

  • Updates on French anti-corruption enforcement, including the first uses of Deferred Prosecution Agreements (CJIPs) generally and in anti-corruption enforcement specifically

  • U.S. enforcement, including the increasing number of U.S. actions resolved with parallel and coordinated cross-border enforcement

  • The annually updated chapter on China, written by Jun He Law Offices

  • Further updates on Brazil, where Operation Car Wash and other investigations continue to ensnare international individuals and companies

Summary of Contents


Chapter 1. The Consequences of Bribery


Chapter 2. Evolution of the International Regulation


Chapter 3. To Whom the Provisions Apply and the Bases for U.S Jurisdiction


Chapter 4. What Conduct Is Prohibited


Chapter 5. Affirmative Defenses and the Exception


Chapter 6. The Accounting Provisions


Chapter 7. FCPA Penalties & Collateral Consequences


Chapter 8. FCPA Opinion Procedure Release Process


Chapter 9. U.S. FCPA Enforcement


Chapter 10. Conducting an Effective Anti-Corruption Internal Review


Chapter 11. Corporate Obligations Under U.S. Law


Chapter 12. Oil, Gas, and Mining


Chapter 13. The Defense Industry


Chapter 14. Pharmaceutical, Medical Device, and Other Health care-Related Companies


Chapter 15. The World Bank & Other Institutions


Chapter 16. France


Chapter 17. Brazil


Chapter 18. The U.K.


Chapter 19 The People’s Republic of China


Appendix * Table of Cases * Index



Bloomberg BNA authors and editors are practicing professionals with insider perspectives and real-life experience. Learn more about this book’s authors and editors.
Kevin T. Abikoff is a partner at Hughes Hubbard & Reed, LLP, Washington, DC. He is Chairman of the firm's Anti-Corruption and Internal Investigations practice group and Co-Chairman of the firm's Securities Litigation practice group and a member of the firm's Executive Committee. 
John F. Wood is a partner at Hughes Hubbard & Reed, LLP, Washington, DC, focusing his practice on providing compliance advice to corporations and conducting internal corporate investigations. 
Michael H. Huneke is a senior associate at Hughes Hubbard & Reed, LLP, Washington, DC.


View full tables of contents and read the book’s preface or introduction.