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FCPA Prevention and Preparedness Lacking
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As the SEC and Department of Justice focus on enforcing the Foreign Corrupt Practices Act, which included $700 million in fines in 2006, a Deloitte online poll found that less than one-third of respondents are increasing internal controls to prevent FCPA violations.
Wendy Schmidt, national leader of Deloitte’s Business Intelligence Services practice, said companies are particularly vulnerable to FCPA violations when acquiring or partnering with foreign firms.
When polled during a Deloitte webcast, “Foreign Corrupt Practices Act: Why Heightened Vigilance Can Be Critical,” more than 620 executives said they believed FCPA violations were most likely in:

Agent/consulting relationships—30.3%

Foreign subsidiaries of U.S. companies—28.4%

Joint venture or strategic alliance partnerships—21.8%
The FCPA makes it a crime for an American citizen or company or foreign company traded on U.S. exchanges to offer, pay or authorize a bribe to a foreign government official to gain a business advantage.
Source: Deloitte FAS, www.deloitte.com.