Not all industry sectors have the same Foreign Corrupt Practices Act risk.
At its most basic level, FCPA risk is a function of real company employees or agents having real points of contact with real alleged “foreign officials” in the global marketplace. The more regulated a foreign marketplace is, the more points of contact there are likely to be.
In many countries, the telecom sector is heavily regulated and thus not surprisingly many FCPA enforcement actions have occurred in this sector.
As highlighted below, since 2010 there have been eleven FCPA enforcement actions against telecom companies resulting in approximately $3.1 billion in settlements. Seven of these enforcement actions were against non-U.S. telecom companies and four of these enforcement actions are in the Top Ten of FCPA settlements.