Where corrupt intent is present, the FCPA prohibits paying, offering, or promising to pay money or anything of value (or authorizing the payment, offer, or promise). Also, as long as the offer, promise, authorization, or payment is made corruptly, the actor need not know the identity of the recipient; the attempt is sufficient. As Congress noted when adopting the FCPA, the word “corruptly” means an intent or desire to wrongfully influence the recipient. By focusing on intent, the FCPA does not require that a corrupt act succeed in its purpose.
A New Era for UK Tax Enforcement: Inside HMRC’s “Breakthrough” Informant Reward Program
For decades, the global gold standard for fighting financial crime has been the U.S. whistleblower reward model—a system that incentivizes insiders to report high-value fraud in exchange for a percentage…
