RopesTalk Culture & Compliance Chronicles: The FEPA Factor—Will the DOJ's Latest Tool Reshape the Landscape of Anti-Corruption Enforcement and Compliance?
Aug 13, 2024
In this discussion, Ryan Rohlfsen, a partner at Ropes & Gray and former DOJ prosecutor, shares his insights on the Foreign Extortion Prevention Act (FEPA). He explains how FEPA could transform anti-corruption enforcement and corporate compliance, highlighting risks for businesses operating internationally. The conversation dives into the cultural nuances of bribery perceptions across different jurisdictions, and the role of whistleblowers in shaping compliance practices. With a blend of legal expertise and practical challenges, Rohlfsen provides a compelling look at the future of anti-corruption strategies.
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FEPA Closes Legal Gaps in Enforcement
- FEPA allows DOJ to directly prosecute foreign officials involved in bribery, closing previous legal loopholes.
- This expansion increases enforcement risks for companies and individuals connected to corruption around the world.
Use FEPA to Strengthen Compliance
- Companies should leverage FEPA's expanded enforcement to emphasize anti-bribery compliance internally.
- Highlight to employees that both giving and receiving bribes now carry greater legal risks.
Diplomatic Nuances Shape FEPA Enforcement
- Diplomatic considerations remain, but DOJ has experts to navigate international relations in prosecuting foreign officials under FEPA.
- DOJ often cooperates with foreign jurisdictions to avoid duplicative prosecutions and respect local enforcement.