Foreign Corrupt Practices Act


Foreign Corrupt Practices Act

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The United States passed the Foreign Corrupt Practices Act (FCPA) in 1977 to prevent corrupt payments to foreign government officials and others considered to act on behalf of others. The FCPA applies to U.S. companies and institutions, as well as foreign companies, institutions or persons connected to the United States and their affiliates.

Questions? Contact University Counsel  or the Office of Sponsored Programs and Research Integrity ( for assistance related to FCPA.   


Components of the FCPA

The FCPA has two components: anti-bribery and accounting.

The Anti-bribery provisions are provided to prevent bribes and/or other payments that are not permitted.

The Accounting items prevent bribes from being hidden by maintaining Generally Accepted Accounting Principles (GAAP).


Penalties for violations can be civil or criminal. They can include fines, imprisonment, disgorgement of any ill-gotten profits, debarment from receiving federal awards, and loss of export control licenses.

Prohibition against corrupt payments appears simplistic and straightforward on its face. In practice, though, the FCPA reflects pitfalls that are far from obvious.

What the FCPA Prohibits
Pitfalls for Universities
How This May Impact You and UCCS
Your Responsibilities