No four-letter word causes more anxiety for today’s top compliance officials than “FCPA.” The Foreign Corrupt Practices Act’s implications are far-reaching, and the consequences of failing to comply with it are devastating. As more companies do business abroad, they’re becoming increasingly vulnerable to violations of the FCPA. At least once a week, we read headlines about bribery allegations or U.S. Securities and Exchange Commission rulings.

Most recently, the SEC pulled the trigger on the second-largest publicly traded firearms company. Smith & Wesson Holding Corporation agreed to pay $2 million to settle charges that it made improper payments to foreign officials while trying to win contracts to supply firearms to military and law enforcement officials overseas. The SEC found the company’s international sales staff “engaged in a pervasive effort to attract new business by offering, authorizing or making illegal payments or providing gifts meant for government officials in Pakistan, Indonesia and other foreign countries.”

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