Understanding the FCPA - ACC.com

FCPA Civil Penalties
Injunctions against future violations of the FCPA
Civil monetary penalties – $10,000 per violation
Forfeiture
Disgorgement of profits resulting from illegal conduct
―Collateral consequences‖ such as debarment – e.g., from
doing business with U.S. government
Denial of export licenses
Tax consequences, e.g., disallowance of deductions and
treating payments by subsidiaries as taxable income to
U.S. parent company
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