Foreign Corrupt Practices Act
FCPA enforcement in the Trade and Geopolitical Risk sector is shaped by a tight cluster of overlapping authorities: the U.S. Department of Justice and the U.S. Securities and Exchange Commission jointly drive criminal and civil exposure, while the U.S. Department of the Treasury's Office of Foreign Assets Control adds a sanctions layer that increasingly runs parallel to bribery investigations involving state-owned trading partners. Scrutiny of third-party intermediaries in sanctioned-adjacent jurisdictions has sharpened since the 2023 joint DOJ-SEC guidance on voluntary self-disclosure, and compliance teams are actively re-auditing distributor and freight-forwarding relationships in Southeast Asia and the Gulf region as a direct result.
Watch
- DOJ Corporate Enforcement Policy: how voluntary self-disclosure credit is calculated for trade-sector violations
- SEC whistleblower awards tied to FCPA tips involving state-owned commodity traders
- Sanctions-bribery overlap cases where OFAC and DOJ have coordinated parallel resolution
- Third-party due diligence gaps flagged in recent FCPA DPAs covering logistics and freight intermediaries
Recent material activity in Trade & Geopolitical Risk
Active monitoring in place across Trade & Geopolitical Risk. Material developments related to foreign corrupt practices act will appear here as they are published.