In the last few months, the President of the United States and the California AG have issued dueling executive pronouncements staking out their positions on enforcement of the FCPA, and companies have been left flummoxed on how to respond. In this guest article, Manatt partners Randy Grossman and Kareem Salem, with associate Andrew Beshai, explain how the California AG is using California’s Unfair Competition Law framework to prosecute foreign bribes and the limitations of the AG’s authority. See “California Bribery Statutes’ Expansive Notion of ‘Official Acts’” (Jan. 29, 2025).
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