Drawing Down Bribery Risks: Complying with the FCPA While Doing Business in Afghanistan in 2014 and Beyond - Global Trade and Customs Journal View Drawing Down Bribery Risks: Complying with the FCPA While Doing Business in Afghanistan in 2014 and Beyond by - Global Trade and Customs Journal Drawing Down Bribery Risks: Complying with the FCPA While Doing Business in Afghanistan in 2014 and Beyond 9 10

Changes in Afghanistan's security environment present challenges for western companies operating in Afghanistan; many will see an increased reliance on local partners, a higher tolerance of dangerous environments, and greater exposure to corruption risks. Given Afghanistan's entrenched culture of corruption, companies must minimize the corresponding risk under the Foreign Corrupt Practices Act ("FCPA"). This article provides a primer on the FCPA's provisions to give compliance personnel guidance. It contains a description of certain payments demanded by the Afghan government from companies supporting U.S. government operations in Afghanistan to illustrate certain difficulties with doing business in Afghanistan as well as a description of the general characteristics of doing business in Afghanistan. It concludes with recommendations for companies doing business in Afghanistan.

Global Trade and Customs Journal