USC Office of Compliance

Who Will You Be Working With On Your Trip?

Foreign Corrupt Practices Act (FCPA)
 
The FCPA makes it unlawful to offer something of value to foreign government officials in order to obtain or retain business, direct business to a particular party or otherwise obtain an unfair advantage.  The business to be obtained or retained need not be with a foreign government or foreign government instrumentality, but may be private.  USC personnel may not offer or make payments to a foreign official in order to:
 

  • influence the individual’s acts or decisions;
  • induce the individual to violate his or her lawful duty;
  • obtain any improper advantage; or
  • induce the foreign official to use his or her influence improperly

 
The prohibited payments need not only be monetary, but may consist of anything of value (e.g., meals or other gifts).  If you have any questions regarding the FCPA and how it may apply to a specific trip, please review the Office of Compliance's FCPA guidance or contact the Office of Compliance.

OFAC
 
When the Treasury Department through the Office of Foreign Assets Controls issues sanctions against a particular country, travel is either greatly restricted or prohibited.  In addition, as part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries.  It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. ("Specially Designated Nationals" or "SDN's.") Their assets are blocked and U.S. persons are generally prohibited from dealing with them.  Please visit http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx for a current list of SDN's, or contact the Office of Compliance for screening assistance.  In addition, review the Office of Compliance's OFAC guidance for more detailed information.