This Guide summarizes the key considerations that Turkish entities and Turkish subsidiaries of U.S. entities face when dealing with the Foreign Corrupt Practice Act ("FCPA"). Turkish entities have faced steep penalties for violating the FCPA in the past, primarily because of compliance failures. As with most extraterritorial US laws, "ignorance of the law is no excuse" and there is no doubt that entities must be prepared to detect, prevent, and remediate possible FCPA violations.
Fortunately, there are many ways to be prepared to comply with the FCPA, and when violations do occur there are potential affirmative defenses, mitigating factors and compliance updates that may avoid or decreased potential penalties.
This Guide is intended to raise awareness and emphasize the importance of establishing necessary compliance programs in line with the FCPA so that entities can detect and prevent corruption before it occurs. Increasing FCPA awareness and developing an understanding is the first step toward FCPA compliance and taking preventative actions against corruption.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.