Companies within the Technology, Media, and Telecom (“TMT”) sector face significant corruption risk given the global nature of the industry and the control exerted by its complex governance structure. Four of the top ten highest FCPA penalties of all time were paid by TMT companies. Opportunities for corruption arise when TMT companies interact with foreign government officials—for example to acquire spectrum licenses and interconnection agreements, bid on government contracts, or satisfy customs requirements. Under the FCPA, TMT companies may also be liable for acts committed by their channel partners.

To read the full article, which includes settlement lessons around evading internal compliance controls and creating off-book funding sources, as well as tips for FCPA compliance, please click here.

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