Foreign Corrupt Practices Act

Overview

The U.S. law (the Foreign Corrupt Practices Act, or “FCPA”) applies primarily to interactions between U.S. persons and foreign officials. 

If you are engaged in activities comparable to the examples below or otherwise involving foreign officials, you must consider the FCPA.  You should familiarize yourself with the definition of foreign official as it is much broader than you might expect.

  • Collaborations with foreign institutions where the partner institution is owned or run by its government
  • Events hosted by Yale on campus or overseas that include foreign officials
  • Projects, sponsored or otherwise, that involve interactions with foreign officials such as projects that require government-issued licenses, approvals or permits
  • Activities that require the hiring of foreign agents or consultants
  • Education programs offered by Yale either overseas or on campus in which foreign officials may enroll

Depending upon the activity and its location, other countries’ laws may also be relevant.  Some, such as the U.K. Bribery Act, are stricter than their U.S. counterpart and may extend to transactions with private persons as well as foreign officials. 

Contact the Office of the General Counsel for assistance with structuring activities that involve non-U.S. participants to comply with the FCPA and other countries’ anti-bribery laws.

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