What is FCPA / UK Bribery Act exposure in M&A?
Acquiring a target with a history of bribery or corrupt payments creates direct successor exposure under the US FCPA and UK Bribery Act 2010. Diligence should include third-party agent screening, gift / entertainment policies, government-touchpoint mapping, and red-flag review of any unusual commission, consultancy or facilitation payments. The UK Bribery Act introduces a corporate strict-liability "failure to prevent bribery" offence with an "adequate procedures" defence.
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