New York-based securities litigation associate Jon Daniels wrote “The Travel Act & Anti-Graft Compliance” for the Oct. 24 issue of Compliance Reporter. The article outlines the U.S. Department of Justice’s use of the Travel Act to target private commercial bribery overseas that would not be restricted by the FCPA. While the Travel Act may be lesser-known than the FCPA or U.K. Bribery Act its implications can be significant for individuals and companies. Each violation of the statute carries a potential penalty of up to $250,000 and five years in jail.
The authors write, “As an initial matter, firms should review and analyze the commercial bribery law of all states in which they operate. Many states have such statutes and several – such as New York and Texas – prohibit the conferring of any improper benefit, regardless of amount… Even companies that have recently adopted strong compliance programs in response to increased FCPA scrutiny should pay careful attention to the concerns raised by Travel Act prosecutions.”
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