Federal law enforcement officials have declared prosecuting the payment of bribes to foreign government officials a top priority – and they are backing up their pledge with aggressive action. Now, more than ever, it is important for companies to ensure they are taking appropriate steps to protect themselves, including some relatively simple and cost-effective steps to ensure compliance with the law.

In 2009, there was a sharp increase in the number of cases filed under the Foreign Corrupt Practices Act, which prohibits payments to foreign officials in exchange for obtaining business opportunities or advantages. While only five such cases were brought in 2004, 40 were brought in 2009, and there is every indication the government will be much more aggressive this year.

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