Foreign Corrupt Practices Act in Africa

Compliance Strategies Given the Sub-Saharan Region's Unique Cultural and Governmental Intricacies

Recording of a 90-minute CLE webinar with Q&A

Conducted on Thursday, October 7, 2010
Recorded event now available

This CLE webinar will prepare counsel to companies doing business in Sub-Saharan Africa to develop, implement and monitor an effective FCPA compliance program. The panel will review recent enforcement focused on Sub-Saharan African operations and the FCPA challenges for doing business in the region (South Africa, Nigeria, Sudan...).


Transparency International’s corruption index shows that perceived corruption is very high in most countries in Sub-Saharan Africa (SSA). Recent and rapid new investment and infrastructure in this region along with the number of companies under state control raise the risk of corruption.

The SEC and the DOJ are increasing scrutiny of U.S. companies doing business with overseas officials and strengthening their FCPA anti-corruption enforcement efforts. American companies conducting business in SSA are more vulnerable than ever to government investigations and charges.

Counsel to companies of any size doing business in SSA must ensure that a rigorous FCPA compliance program is implemented and monitored.

Listen as our authoritative panel examines the risk factors of FCPA violations in SSA, the lessons learned from recent enforcement actions, and offers strategies for mitigating the risk of FCPA violations.


  1. Risk factors of doing business in Sub-Saharan Africa
    1. Defining government officials
    2. Defining a bribe
    3. Exposure to third party you may not control
    4. SSA business culture/practices
    5. Reach of the FCPA in SSA
  2. Intersection of FCPA and local anti-bribery laws
    1. Congruency of the laws
    2. Enforcement of local anti-bribery laws
    3. FCPA affirmative defense to prohibition of payment that was lawful under rules/regulations of the country
    4. Gift giving
  3. Lessons learned from recent enforcement action
  4. Best practices for mitigating risk
    1. Monitoring
    2. Compliance program
    3. Internal controls
    4. Education/training
    5. Due diligence
    6. Steps if misconduct is suspected


The panel will review these and other key questions:

  • What are the key risk factors exposing companies conducting business in Sub-Saharan Africa to possible FCPA violations?
  • What lessons can be learned from recent SEC and DOJ enforcement efforts aimed at companies doing business in Sub-Saharan Africa?
  • What are the best practices for companies to utilize in developing anti-corruption compliance programs and due diligence efforts for their Sub-Saharan African operations?


Thomas R. L. Best, Attorney
Steptoe & Johnson, Washington, D.C.

He focuses on representing clients in FCPA enforcement actions before the U.S. Department of Justice and Securities and Exchange Commission. He has led FCPA internal investigations in many countries, including throughout West Africa. He helps clients design and implement compliance programs addressing the risks associated with the intersection of the FCPA and other nations’ anti-corruption laws.

Herbert A. Igbanugo, Shareholder
Igbanugo Partners Int'l Law Firm, Minneapolis

He heads the firm's International Trade Law group focusing exclusively on Sub-Saharan Africa. He assists clients doing business in Sub-Saharan Africa with anti-corruption training and immigration matters. He is well versed in African-governmental relations development, lobbying and interest advocacy. He was invited to serve as a delegate in President Clinton’s historic trip to Sub-Saharan Africa.

Obiamaka P. Madubuko, Partner
McDermott Will & Emery, New York

She specializes in anti-corruption and fraud matters, advising companies on a host of compliance and transactional due diligence issues arising under the Foreign Corrupt Practices Act, Office of Foreign Asset Control and other global trade regulations. She has extensive experience involving the FCPA in sub-Saharan Africa and has published a chapter on how to manage FCPA risks in sub-Saharan Africa


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