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The SEC and DOJ, who have jurisdiction over enforcement of the Foreign Corrupt Practices Act ("FCPA"), have long viewed certain countries as hotbeds of corruption and, as a result, have focused FCPA investigations in these geographical areas. So what can U.S. companies doing business internationally do to ensure they stay on the right side of the FCPA? One basic first step companies can take is to understand which countries present the greatest risks of corruption – and consequently, a heightened risk of FCPA violations – and focus compliance efforts accordingly.

The most recent
Corruption Index survey by Transparency International shows that Somalia, North Korea, and Afghanistan are tied for the dubious honor of most corrupt countries in the world. And without further ado, in order of reported levels of corruption, the  21 countries that pose the greatest FCPA threat to your business are:

1. Somalia
1. North Korea
1. Afghanistan
4. Sudan
5. South Sudan
6. Libya
7. Iraq
8. Uzbekistan
8. Turkmenistan
8. Syria
11. Yemen
12. Haiti
12. Guinea Bissau
12. Equitoreal Guinea
12. Chad
16. Venezuela
16. Eritrea
16. Cambodia
17. Burundi
17. Myanmar
17. Zimbabwe 

If your company is doing business internationally – and especially if it is doing business in any of the hot spot countries on the list above – check out my recent blog post. It explains why investing in a robust FCPA compliance program can save your company enormous costs by potentially avoiding prosecution for FCPA violations by rogue employees. It also gives seven practical tips your company can take to implement an effective FCPA compliance program.

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