EMBARGOED AND RESTRICTED

摘要

Since 1977, the Foreign Corrupt Practices Act or FCPA has been at the forefront of United States legislation aimed at targeting anti-corruption. We are witnessing ever-increasing penalties being imposed against companies that have failed to comply with this legislation. Currently, Siemens is facing US$1.6bn (£975m) in penalties with a number of ongoing criminal prosecutions affecting senior managers. However, the latest penalty to send Shockwaves across the Atlantic was delivered by another of the US's many enforcement bodies, the Office of Foreign Assets Control (OFAC). OFAC has penalised Lloyds TSB £350m for various breaches of laws aimed at preventing trade or business links with countries or individuals deemed by the US as embargoed or restricted.