The author examines the Foreign Corrupt Practices Act (FCPA), the Omnibus Trade and Competitiveness Act of 1988, and some of the cases decided under each bill. A survey of the Chief Legal Counsels of Fortune 500 companies was done to determine whether U.S. corporations had adopted new codes of ethics and/or conduct to ensure their firms’ compliance with the FCPA and its amendments. The survey also studied whether the firms had changed their sales and marketing practices after these laws were passed. The results indicate that many of the responding firms made some changes; however, new allegations of foreign bribery by American firms probably indicate that vigorous enforcement of the FCPA must be continued.
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