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

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Conducted on Thursday, October 7, 2010

Recorded event now available

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Course Materials

This CLE course 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?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


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

Steptoe & Johnson

He focuses on representing clients in FCPA enforcement actions before the U.S. Department of Justice and Securities and...  |  Read More

Herbert A. Igbanugo
Herbert A. Igbanugo

Igbanugo Partners Int'l Law Firm

He heads the firm's International Trade Law group focusing exclusively on Sub-Saharan Africa. He assists clients doing...  |  Read More

Obiamaka P. Madubuko
Obiamaka P. Madubuko

McDermott Will & Emery

She specializes in anti-corruption and fraud matters, advising companies on a host of compliance and transactional due...  |  Read More

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