Tax and Accounting Risks of Foreign Corrupt Practices Act Violations

Facilitating Payments Exceptions, FCPA Internal Controls, Monitoring Subsidiaries and Third Parties

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

Wednesday, July 17, 2019

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

or call 1-800-926-7926

This webinar will provide practical guidance to corporate tax advisers on the tax and accounting implications of the Foreign Corrupt Practices Act (FCPA) for U.S. companies with foreign operations.


The Department of Justice and the SEC continue to aggressively investigate and bring enforcement actions under the FCPA against individuals and U.S. companies operating outside of the United States. The FCPA prohibits the payment of "anything of value" to "foreign officials," including political candidates or political parties, with the intent to influence the actions of those foreign officials or to secure an undue business advantage. The FCPA also requires “issuers” to maintain accurate books and records and implement internal accounting controls to prevent the misuse of assets.

The FCPA directly impacts corporate tax and accounting departments. Dealing with tax authorities outside the United States could create risk under the FCPA’s anti-bribery provisions. In addition, the accounting provisions require tax and accounting departments to ensure the accurate recording of company transactions and the implementation of internal controls to safeguard company assets. In addition, tax and accounting professionals must understand that fines and disgorgement ordered through FCPA resolutions have consequences for proper recording and tax treatment.

Listen as our authoritative panel provides practical guidance to corporate tax advisers on the accounting and tax challenges of complying with the internal controls requirements of the FCPA.



  1. FCPA provisions and prohibitions
  2. Facilitation payments exemption
  3. FCPA risks when partnering with foreign quasi-governmental entities
  4. Internal controls provisions
  5. Section 162(c) tax risks of mischaracterized expenditures
  6. IRS treatment of disgorgement settlements under Section 162(f)


The panel will review these and other key issues:

  • What corruption risks do tax and accounting departments face?
  • What compliance safeguards and internal controls can mitigate those risks?
  • How can tax and accounting departments ensure their companies accurately record transactions and flag suspect transactions?


Montenegro Almonte, Alejandra
Alejandra Montenegro Almonte

Miller & Chevalier

Ms. Montenegro Almonte's practice focuses on the area of international regulatory compliance and enforcement across...  |  Read More

Tillen, James
James G. Tillen

Miller & Chevalier

Mr. Tillen is Vice Chair of the firm’s International Department. His practice focuses on matters involving the...  |  Read More

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