FCPA Landmines Beneath the Surface of the COVID-19 Crisis

As governments, healthcare providers, and others are scrambling to procure critical medical equipment and protective gear on an expedited basis, and manufacturers around the world are positioning themselves to produce and supply it, the global supply chain landscape is replete with Foreign Corrupt Practices Act landmines. Sheppard Mullin warns that well-intending companies hoping to partner with foreign equipment and PPE manufacturers could become a casualty if they don’t watch their step. The DOJ and SEC have been aggressive in enforcing the FCPA in recent years, an approach they are likely to continue, in hopes of deterring abuses during the current health crisis.