Simply put, No. Foreign persons acting in the U.S. are subject to the FCPA, as well as U.S. subsidiaries of foreign companies. The country of domicile has become far more irrelevant in modern times where technology has made money more fungible and communications seamless. Multinational companies operating on a global basis need to be wary of FCPA compliance, even if they are not U.S.-domiciled, as their actions could create such liability in many distinct ways, with the government seeking potentially expansive definitions of what it means to be “acting in the U.S.”
Whistleblower Justice Network has an international team of FCPA experts fully-versed in the varied issues that arise related to the Foreign Corrupt Practices Act. WJN works alongside our clients, with our compensation being 100% success-based, to guide them through every aspect of how to report FCPA violations to the SEC Whistleblower Program. Together with our clients, we make a difference.
If you have significant information about FCPA violations, Whistleblower Justice Network can help you become a successful whistleblower under the SEC Whistleblower Program. Our clients benefit from our expertise, extensive relationships and 20+ years of combined experience as whistleblowers. Contact us today for your free, 100% confidential consultation.