About Investigating Corporate Corruption

These materials support a simulation course in which students investigate a potential violation of the Foreign Corrupt Practices Act (FCPA). This course book, which supports a simulation course, introduces students to the FCPA and provides skills primers on interviewing a witness and counseling a client. By using this dynamic book in a simulation-style course, students will not only learn about the FCPA, but they will also engage in essential lawyering skills, including fact development and analysis, interviewing, counseling, team building, project management, and problem-solving.


The Readings include materials relating to the FCPA and skills primers teaching students how to interview witnesses and counsel clients. The FCPA materials include a description of the purposes of the FCPA and its most important provisions, along with information about DOJ and SEC enforcement. The skills primers instruct students on the steps involved in these essential lawyering activities.

Legal Sources

The Legal Sources include statutory provisions, a case, a DOJ opinion, a published settlement agreement, and excerpts from the DOJ/SEC enforcement guide relating to the “foreign official” element of the FCPA and the question whether charitable contributions can violate the statute.