FCPA and Other Anti-Corruption Concerns Facing Sovereign Wealth Funds

by Luke Cadigan, Robert Hadley, Elizabeth Robertson, Amy Sommers

Sovereign Wealth Funds (SWFs) wield a staggering amount of financial influence. Given all the money at issue, U.S. prosecutors have expressed a clear concern about the risk of corruption in dealings with these funds.  Indeed, both the U.S. Department of Justice (DoJ) and the U.S. Securities and Exchange Commission (SEC) have indicated an interest in examining transactions involving SWFs for possible violations of the U.S. Foreign Corrupt Practices Act (FCPA).

This article addresses the potential liability that SWFs face under three of the most significant antibribery laws:  the U.S. FCPA, the U.K. Bribery Act, and the People’s Republic of China’s Antibribery Laws.

FCPA and Other Anti-Corruption Concerns Facing Sovereign Wealth Funds