FCPA from 1977
The FCPA prohibits private persons, public officials, companies, their employees and intermediaries from making payments or financial contributions to foreign public officers in order to be granted tender for a transaction or in order to maintain a business relationship. The US Constitution calls for a worldwide area of application: If, in a case of bribery by non-American public officials and function owners, a connection, e.g. of a financial nature, is made to the USA, then this may be lead to serious penalties for foreign companies and their institutions. Amongst other things, the FCPA demands an effective compliance programme which is to include a whistleblowing system pursuant to the 2012 guidelines “A Resource Guide to the U.S. Foreign Corrupt Practices Act” (Hallmark No. 8, p. 61).
See The United States Department of Justice at: www.justice.gov/criminal-fraud/statutes-regulations (accessed on 08.06.2020).