FCPA Compliance in the Middle East: Strategies Given the Region's Unique Cultural and Governmental Intricacies

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

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Conducted on Wednesday, May 20, 2015

Recorded event now available

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Course Materials

This CLE course will provide guidance for counsel to companies doing business in the Middle East to develop and implement an FCPA compliance program. The panel will review recent enforcement focused on Middle Eastern operations and the FCPA challenges for doing business in the region.


The SEC and the DOJ continue to closely scrutinize U.S. companies operating overseas, and the agencies' FCPA anti-corruption enforcement efforts show no signs of abating. U.S. and U.S.-related companies conducting business in the Middle East must be particularly cognizant of anti-corruption issues due to the uncertain politics of the region and the perception of significant public sector corruption.

Recent FCPA-related enforcement actions, including a record fine of $772 million paid by Alstom SA in Dec. 2014, remind counsel to companies of all sizes of the necessity of implementing an effective FCPA compliance program that is tailored to a company's profile, adapted to local risk, and continually evolving to address emerging compliance challenges.

Listen as our authoritative panel examines the risks of doing business in the Middle East, conduct that may trigger FCPA violations, and the lessons learned from recent enforcement action. The panel will offer strategies for mitigating risk.



  1. Risk factors of doing business in the Middle East
    1. Defining government officials
    2. Defining a bribe
    3. Exposure to third party you may not control
    4. Middle Eastern business culture/practices
  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. Best practices for mitigating risk
    1. Monitoring
    2. Compliance program
    3. Internal controls
    4. Education/training
    5. Due diligence


The panel will review these and other key issues:

  • What are the key FCPA risk factors for business in the Middle East?
  • What lessons can be learned from recent SEC and DOJ enforcement efforts relating to business in the Middle East?
  • What are the best practices for companies in developing anti-corruption compliance programs and due diligence efforts for their Middle East operations?


Thomas R. L. Best
Thomas R. L. Best

Steptoe & Johnson

Mr. Best's practice is focused on international investigations, enforcement, compliance and mergers and...  |  Read More

Marc Alain Bohn
Marc Alain Bohn

Miller & Chevalier

Mr. Bohn focuses on the FCPA and other areas of international corporate compliance, and regularly advises multinational...  |  Read More

John Vincent Lonsberg
John Vincent Lonsberg

Baker Botts

Mr. Lonsberg's practice focuses on international transaction, regulatory and dispute resolution. He has...  |  Read More

Chung, Daniel P.
Daniel P. Chung

Of Counsel
Gibson Dunn & Crutcher

Mr. Chung is an experienced trial and appellate attorney, and his practice focuses on white-collar criminal defense,...  |  Read More

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