The notion of extra-territorial enforcement of anti-corruption law first emerged in 1977 with the passage of the US Foreign Corrupt Practices Act, which prohibits bribery of foreign officials as a means of obtaining or retaining business, and holds parent companies liable for illegal actions taken by subsidiaries. Of great concern to US companies was the fact that the FCPA’s reach did not extend to non-US companies unless they had a US listing or operational presence.
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