The Foreign Corrupt Practices Act (FCPA) is integral to the United States’ global anti-corruption efforts. Designed to prohibit U.S. companies and their representatives from bribing foreign officials to gain business advantage, the FCPA has long been a critical regulatory framework for multinational companies operating worldwide. However, the recent executive order under the current U.S. administrationpausing FCPA enforcement for 180 days, has sparked significant debate. This pause introduces a layer of uncertainty for companies operating in complex jurisdictions like Nigeria where corruption risks are prevalent, particularly in sectors like oil and gas, infrastructure and government procurement. While some companies may perceive the pause as a reprieve from rigorous compliance, the reality is quite contrary. Nigeria’s stringent anti-corruption laws, alongside global regulations like the UK Bribery Act and France’s Sapin II, remain in full force. This article explores the implications of the FCPA enforcement pause and how multinational companies in Nigeria can strategically balance compliance with business growth while the pause remains in effect.
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