China Matters: Technology Companies Operating in Asia Remain a Focus for FCPA Enforcement
By Lesli Ligorner, Morgan Miller, Palmina Fava & Rebecca McGuire
Technology companies doing business in Asia continue to face increased scrutiny by federal regulators for potential violations of the Foreign Corrupt Practices Act (FCPA). In recent months, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have dramatically increased the number of FCPA investigations involving business activities in Asia, particularly in China. This focus is compounded by the long-standing scrutiny of technology companies, which have historically strong ties to suppliers and manufacturers in the region. Following the SECs formation of a San Francisco-based FCPA unit designed specifically to target technology firms operating in Asia, we expect technology companies will continue to be in the crosshairs of government regulators for the foreseeable future.