Foreign Corrupt Practices Act

Defense and government contractors face one of the sharpest FCPA enforcement concentrations of any sector, where the U.S. Department of Justice and the U.S. Securities and Exchange Commission have repeatedly used the statute's anti-bribery and books-and-records provisions to pursue conduct tied to foreign procurement, offset arrangements, and third-party agent networks. The U.S. Department of Defense's own contractor compliance expectations, layered on top of DOJ's Corporate Enforcement Policy, mean that a single deficient internal investigation can convert a disclosed violation into a debarment risk. Cresthaven is actively monitoring this intersection for new enforcement actions, policy guidance, and agency statements as they land.