Risk Management for Multinational Corporations: Sentencing Guidelines Proposals Reflect Evolving Compliance Norms

Abstract

In recent years, the U.S. government has become increasingly aggressive in enforcing U.S. laws designed to regulate international conduct of multinational corporations. As a result, multinational corporations face multiplying compliance concerns as they seek to comply with U.S. sanctions and antimoney laundering requirements, export control rules, and the Foreign Corrupt Practices Act (FCPA). In this article, the author develops the proposed amendments and their implications for multinational corporations attempting to manage the risks posed by these complicated and nuanced laws.