Parent Company and Subsidiary Liability for FCPA Violations: Fighting the Disinformation Campaign

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1 Response

  1. Gustavo says:

    Excellent article Mike. The topic is critical and many times ignored in decisions by relevant players.
    When you talk about the parent company, are you referring to companies subject to FCPA who control the foreign subsidiary?
    Another scenario: If the company subject to FCPA (eg a US-based corporation) owns a minority interest in the foreign subsidiary, which is under control of a company not subject to FCPA (eg based in a European or Asian country and does not quote stock or debt under the SEC), would you say that the US-based company may not bu subject to FCPA liability for the actions of the foreign subsidiary and it may be subject to FCPA liability for its own actions?