Amid all the changes, one big question remains: Will the changes apply equally to U.S. companies that undercut other U.S. firms abroad, or will enforcement continue to focus mainly on non-U.S. companies with ties to U.S. markets? We won’t know for sure until we see the impact of the new FCPA enforcement framework in action. But we do know the goal is an approach that is both narrower and faster. For companies operating globally, that sounds like both a warning and an opportunity.
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