ABSTRACT
Companies also developed anti-corruption programs with the purpose of preventing and detecting inappropriate behaviors and promoting a healthy corporate culture. To combat global corruption, American companies helped create the NGO Transparency International, founded in 1993, based in Berlin, Germany, and aimed at combating corruption. Companies are subject to extortion and some of them pay bribes. Consequently, the private sector is part of the problem, but if the private sector takes necessary precautions, it can also be part of the solution. The Foreign Corrupt Practices Act (FCPA) provides that bribes to foreign officials by US companies, their branches or companies listed on the New York Stock Exchange, are prohibited. The FCPA sanctions any payment made to third parties with the knowledge that all or part of the payment will be used to bribe a foreign government official. This situation is considered “willful blindness” or deliberate ignorance of the fact that the intermediary will break the law.
