Jurisdiction(s):
United Kingdom

A UK lawyer’s guide to US FCPA internal investigations, enforcement, self-reporting, DOJ/SEC policies, privilege, DPAs/NPAs, M&A successor liability, and cross-border co-operation

Published by a LexisNexis Corporate Crime expert

Practice notes

Stop Press:

On 10 March 2026, the US Department of Justice (DOJ) unveiled its first department-wide corporate enforcement and voluntary self-disclosure policy for criminal matters, intended to enhance consistency and fairness in pursuing white-collar offences. For further details, see: US DoJ releases first department-wide corporate enforcement policy for criminal matters, LNB News 11/03/2026 57. This Practice Note is currently being updated to reflect the corporate enforcement policy.

The US Foreign Corrupt Practices Act of 1977 (FCPA) is a US federal statute that outlaws offering, paying, or promising money or anything of value to a foreign official with the objective of obtaining or retaining business. The UK Bribery Act 2010 (BA 2010) (together with earlier UK legislation on bribery and corruption) is viewed as the FCPA’s closest counterpart. Although the regimes share certain features, there are significant distinctions between them.

This Practice Note examines the principal issues that emerge during investigations and enforcement relating to potential FCPA breaches and delivers practical guidance for practitioners engaging with US enforcement authorities, the US Securities and Exchange Commission (SEC), and the US Department of Justice (DOJ), as well as information on international co-operation and...

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Amanda Raad , Esq

Ropes & Gray

Co-leader of Ropes & Gray’s global anti-corruption and international risk practice and co-founder of R&G Insights Lab, Amanda Raad serves as a trusted advisor to clients seeking wide-ranging counsel on global and cross-border risk. Qualified in the United States and as a Solicitor in England and Wales, she leverages her extensive knowledge and experience of these active enforcement regimes to help clients navigate risk across jurisdictions. Amanda represents clients across every business sector in criminal enforcement and regulatory matters, internal investigations, and compliance matters involving a range of misconduct, including financial fraud, corruption, sanctions and export control violations, money laundering, cybersecurity and data privacy issues, antitrust issues, and sexual misconduct. Amanda also works with clients in creating compliant cultures. Amanda publishes and speaks frequently on cross-border challenges in the areas of corporate crime and investigations, including those associated with sexual...

Web page updated on 21/05/2026

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