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Home›Courses›Safety Training›The Foreign Corrupt Practices Act Made Simple

The Foreign Corrupt Practices Act Made Simple

18 minutesEN / ESSafety TrainingForeign Corrupt Practices Act (15 U.S.C. 78dd-1 et seq.)
Quick Answer

The Foreign Corrupt Practices Act Made Simple is an 18-minute online course that teaches employees the key provisions of the FCPA, including anti-bribery prohibitions, accounting and recordkeeping requirements, and the consequences of non-compliance. It is designed for employees at companies engaged in international business and includes a downloadable certificate of completion.

Course Overview

The Foreign Corrupt Practices Act (FCPA) is one of the most aggressively enforced anti-corruption laws in the world. In 2024, the DOJ and SEC collected over $1.5 billion in FCPA-related penalties, the highest total in five years. Individual violators face criminal fines up to $250,000 per violation and up to five years in prison, while companies can be fined up to $2 million per criminal violation. Even after a temporary enforcement pause in early 2025, the DOJ resumed enforcement under updated guidelines, making compliance training more important than ever for organizations with international operations.

This course breaks down the two core components of the FCPA for your employees: the anti-bribery provisions that prohibit offering anything of value to foreign government officials to obtain or retain business, and the accounting provisions that require publicly traded companies to maintain accurate books and records with adequate internal controls. Your team will learn to recognize red flags for potential FCPA violations, understand the facilitating payments exemption, and know the steps to take when they encounter suspicious activity.

What You'll Learn

  • The two primary components of the FCPA: anti-bribery provisions and accounting requirements
  • Definition of foreign official under the FCPA and its broad jurisdictional reach
  • Prohibited payments, gifts, and anything of value offered to influence foreign officials
  • The facilitating payments exemption and its evolving interpretation
  • Books and records requirements for publicly traded companies
  • Criminal and civil penalties for individuals and organizations
  • Red flags for potential FCPA violations in third-party relationships

Who Needs This Training

  • Employees at companies with international business operations or foreign subsidiaries
  • Sales and business development staff who interact with foreign government officials or agents
  • Finance and accounting professionals responsible for international transaction records
  • Compliance officers and legal staff managing anti-corruption programs
  • Procurement teams working with third-party agents and distributors overseas
  • Senior executives and board members with oversight of global operations

Regulatory Background

The Foreign Corrupt Practices Act (15 U.S.C. 78dd-1 et seq.) was enacted by Congress in 1977 to combat bribery of foreign officials by U.S. businesses. Enforcement is shared between the Department of Justice, which handles criminal prosecutions, and the Securities and Exchange Commission, which pursues civil enforcement actions against publicly traded companies. In 2024, U.S. authorities brought 26 FCPA enforcement actions and recovered over $1.5 billion in combined penalties. Companies found in violation face criminal fines up to $2 million per violation, while individuals face up to $250,000 in fines and five years imprisonment. Courts may also impose fines of up to double the gross gain from the corrupt activity. The FCPA's reach extends beyond U.S. companies to include foreign corporations with U.S.-listed securities and any person who commits an act of bribery while in the United States.

Frequently Asked Questions

Yes. The FCPA's anti-bribery provisions apply to all U.S. domestic concerns, which includes any U.S. citizen, national, or resident, as well as any business entity organized under U.S. law or with its principal place of business in the United States. Private companies are fully subject to the anti-bribery provisions. The accounting and internal controls provisions, however, apply specifically to issuers with securities registered under the Securities Exchange Act.
A bribe is a payment made to a foreign official to obtain or retain business or secure an improper advantage. A facilitating payment is a small payment made to expedite routine governmental actions that the official is already obligated to perform, such as processing permits or scheduling inspections. While the FCPA includes a narrow exemption for facilitating payments, this exemption is interpreted very narrowly by enforcement authorities, and many companies prohibit facilitating payments entirely as a matter of policy.
Individuals who violate the FCPA's anti-bribery provisions face criminal penalties of up to $250,000 per violation and up to five years in prison. Civil penalties can reach $10,000 per violation. Courts may also impose criminal fines of up to twice the gross gain or loss from the illegal conduct. Importantly, companies are prohibited from paying fines imposed on their employees, meaning individual liability cannot be shifted to the employer.
Yes. The FCPA holds companies liable for corrupt payments made by third-party agents, consultants, distributors, and joint venture partners if the company knew or had reason to know that the payment would be used for prohibited purposes. This is why adequate due diligence on third-party relationships and ongoing monitoring of agent activities are critical components of an effective FCPA compliance program.
Many countries have enacted their own anti-corruption statutes that may apply in addition to the FCPA. The UK Bribery Act 2010, for example, is broader in some respects, covering both public and private sector bribery and imposing strict liability on companies that fail to prevent bribery. Companies operating internationally must comply with all applicable anti-corruption laws in each jurisdiction where they do business, and enforcement authorities frequently coordinate across borders on major investigations.

Related Courses

Organizations with employees who handle international business often pair FCPA training with Workplace Ethics Made Simple to reinforce ethical decision-making across all operations. For companies needing broader compliance coverage, the Workplace Compliance (HR) bundle addresses harassment prevention, anti-discrimination, and workplace conduct standards.

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$24.95
per person
Volume Pricing
Team Size Price per Person
1 - 9$24.95
10 - 24$19.95
25 - 49$17.95
50 - 99$17.50
Subtotal $24.95
Language

This course is available in English and Spanish at no additional charge.

Certificate of completion included. Downloadable upon passing the final assessment.

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$24.95
per person