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Joint Ventures and FCPA Risk Management


This article written by John L. Rudy (Senior Counsel at Deere & Company) and Anshu Pasricha (Shareholder at Koley Jessen) addresses the continuing trend of expanding enforcement of the Foreign Corrupt Practices Act (FCPA), which creates a heightened risk for businesses participating in international transactions. Often overlooked is the liability present for a non-controlling, minority investor in a joint venture project (a non-controlling JV partner). Despite their lack of authority, a non-controlling JV partner can be “on the hook” for any FCPA violation made during the process. This threat accentuates the necessity of proactive risk mitigation efforts and must be considered against the potential economic benefit of participating as a non-controlling JV partner. The article discusses strategic considerations for FCPA compliance from the perspective of a non-controlling JV partner.

Reprinted with permission of the authors and the Association of Corporate Counsel as it originally appeared: John L. Rudy, Anshu Pasricha, “Joint Ventures and FCPA Risk Management,” ACC Docket (December 2016): 36-31. Copyright © 2016, the Association of Corporate Counsel. All rights reserved.

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