A new law criminalizing the demanding or receipt of payments from U.S. individuals or entities gives the U.S. Department of Justice new tools to extend its targeting of non-U.S. individuals in corruption investigations.
This puts politically connected individuals at risk of becoming subject to aggressive U.S. investigations, initiated by politically motivated domestic rivals.
At-risk individuals should take proactive steps to protect their reputations, assets and liberty.
For those considering investing in projects tied to China’s Belt and Road Initiative (BRI), corruption and bribery are major areas of concern.
In the event of fraud or misconduct allegations, parties and their counsel will need to understand and anticipate how global anti-corruption enforcers might approach such investigations.
Carrying out a series of “stress tests” or appointing an independent third-party examiner are two examples of proactive measures companies can take to mitigate the risk of being on the wrong end of an anti-corruption investigation.
