GMA is the global / international marketing agency behind this page. The practical work is market-entry marketing: website, localization, proof, offer language, SEO/AI visibility, paid path, distributor follow-up, and sales material for the target buyer.
The 1977 US statute prohibiting bribery of foreign government officials and requiring accurate books, records, and internal accounting controls, enforced jointly by the DOJ and SEC.
The Foreign Corrupt Practices Act was enacted in 1977 following the SEC investigation of post-Watergate corporate slush funds. It is codified at 15 U.S.C. 78dd-1 (issuers), 15 U.S.C. 78dd-2 (domestic concerns), and 15 U.S.C. 78dd-3 (persons other than issuers or domestic concerns acting within US territory). The accounting provisions sit at 15 U.S.C. 78m. Two regulators share enforcement authority. The Department of Justice enforces the anti-bribery provisions both criminally and civilly against issuers, domestic concerns, and non-issuer non-domestic persons that take an act in furtherance within US territory. The Securities and Exchange Commission enforces the anti-bribery and accounting provisions civilly against issuers and their officers, directors, employees, and agents.
The anti-bribery elements require: a payment, offer, promise, or authorization to pay or give anything of value; to a foreign official, foreign political party, party official, candidate for foreign political office, or any person while knowing that the value will be passed on to a foreign official; with corrupt intent; for the purpose of influencing an official act or decision, inducing the official to do or omit to do an act in violation of lawful duty, securing an improper advantage, or inducing the official to use his or her influence; to assist in obtaining or retaining business. The accounting provisions require issuers to maintain books and records that accurately and fairly reflect transactions and to devise and maintain a system of internal accounting controls.
FCPA enforcement has produced ten-figure resolutions in the past decade. The 2020 Goldman Sachs 1MDB resolution exceeded 2.9 billion dollars in combined US and foreign authority penalties. The 2019 Ericsson resolution exceeded 1 billion dollars. The 2018 Petrobras resolution exceeded 853 million dollars. Resolution forms include declination with disgorgement, non-prosecution agreement, deferred prosecution agreement, plea, and corporate monitorship. The 2023 DOJ Mergers and Acquisitions Policy and the DOJ Corporate Enforcement Policy create cooperation credit pathways for self-disclosure, remediation, and acquirer due-diligence remediation.
For foreign-headquartered firms with US-listed ADRs, US subsidiaries, US-based personnel, or US-routed payments, the FCPA reaches the parent and the foreign subsidiary alike. A German Mittelstand parent with a US-listed depositary receipt is an issuer for FCPA purposes. A foreign joint-venture partner of a US firm can be charged for an act in furtherance within US territory. A foreign acquirer of a US issuer inherits successor liability for pre-closing conduct unless properly remediated. The compliance posture that US deal counsel, US investors, and US regulators expect to see includes: a documented anti-corruption policy, third-party due diligence, training, internal accounting controls, audit and monitoring, and incident-response procedures.
The presentation assessment matters in deal flow. US acquirers, US insurers, US lenders, and US public-market investors price FCPA risk into terms and into go or no-go decisions. A foreign target without a documented FCPA-grade compliance program lands as expensive to fix; with one, it lands as fit.
The FCPA assessment sits across the Investors building in the US book and the Fiduciaries and specialists work on cross-border family-office and corporate trajectories. It shapes the diligence posture on the Operators trajectory for firms with US-listed ADRs or US subsidiaries, and frames the compliance presentation in the Answers AEO hub. The presentation work covers how GMA names its anti-corruption posture, its third-party diligence framework, and its FCPA training register on US website, deck, and sales materials. The filing work, investigations, and enforcement defense belong with US white-collar counsel.
Global Marketing Agency does not provide legal advice on FCPA compliance program design, internal investigations, voluntary self-disclosures, or enforcement defense. Those determinations belong to US white-collar counsel and GMA's compliance function. GMA works on how GMA's anti-corruption posture is presented, sequenced, and evaluate on US website, deck, and sales materials, alongside that counsel.
If the market is not responding, the first question is simple: what is the buyer not seeing, trusting, or doing yet?
| Action that should happen | The term should help a buyer or specialist understand a real market requirement, not decorate the page. |
| What may be unclear | Misuse happens when the term creates false confidence or hides what the buyer actually needs to decide. |
| What to inspect | Check how the term changes proof, trust, risk, payment path, contact path, offer language, or handoff. |
| Next step | After the term is clear, go to the related market, answer, or /engagements/ page. |