John W. Duncan


This comment will examine the Senate's proposed amendment to the FCPA, taking into consideration the resulting economic, political, and moral burdens. The first section reviews criticisms of the FCPA's accounting and anti-bribery provisions. The following section analyzes whether and how the Business Practices and Records Act (BPRA) addresses the FCPA's shortcomings. in addition, this comment discusses possible effects of the Senate's proposal on the possibility of a multilateral agreement on corrupt payments to foreign officials, and on purely private transactions.