The document outlines the key elements of violations under the U.S. Foreign Corrupt Practices Act, including that there must be: 1) corrupt intent by an actor such as an individual or firm, 2) payment or offer of value, 3) to a foreign official or political candidate/party, 4) to obtain or retain business. It also discusses intermediaries, due diligence requirements to avoid liability, red flags of potential violations, and sanctions for violations including criminal fines and loss of ability to contract with the U.S. government.

1. The U.S. Foreign Corrupt Practices Act Thomas O’Dea VP International Sales March 15, 2010