Overview
Steptoe's Lucinda Low, Brittany Prelogar, Zoe Osborne and Jessica Piquet Megaw co-authored an article titled "Commercial Bribery: The FCPA's Forgotten Counterpart" for the Anti-Corruption Report. In the article, the authors argue that corporate prohibitions on public sector bribery are insufficient to mitigate anti-corruption enforcement risks related to commercial bribery and that compliance programs should be reevaluated to fully mitigate this risk.
The full article can be read at the Anti-Corruption Report (subscription required).