By use of this website and/or by creating an account with the Foreign Corrupt Practices Act Clearinghouse (FCPAC), you consent to the following privacy policy in addition to Stanford’s Online Privacy Policy:

When you first sign up with the FCPAC, we will collect and process the following types of information from you: name, email, affiliation, and industry. Your name and email address are used solely for the purpose of creating your account and generating your username, and for sending email updates to users who voluntarily subscribe to receive such updates.

We may use anonymized web analytics to track user demographics, the types of searches our users run, and the pages our users visit while on the FCPAC website. These analytics allow us to understand what features are of greatest interest to users, to enhance the features and services that we offer to our users, and to improve the user experience. We may share anonymized web analytics and anonymized user information with Sullivan & Cromwell LLP and with academics for research purposes. We may also share data internally with others at Stanford University and with third parties pursuant to valid legal process, as described in the Stanford Online Privacy Policy.

You can choose to save searches performed on the Advanced Search form. Those searches will be saved to your account indefinitely, or until you delete the searches or your account information.

You have the option to delete your account information from our system at any time.

For information about Stanford University's online privacy policy, please click here.

Limitations on Use:

The Foreign Corrupt Practices Act Clearinghouse (FCPAC) is a free public database and website designed to support corporate board members, executives, regulators, policy makers, journalists, lawyers, compliance personnel, scholars, and the broader community in their understanding and awareness of FCPA enforcement activity. Users of the FCPAC can register to receive free email notifications of recent FCPA enforcement actions, settlements, opinions, and new investigations ("Email Notifications").

The FCPAC includes materials created by third parties, and serves as a repository of press releases, court and administrative filing and settlement documents, court orders, dockets, and other enforcement-related materials ("Third-Party Materials"). The FCPAC does not own any of the intellectual property associated with the Third-Party Materials. Accordingly, Stanford University cannot grant or deny permission to use such materials and does not assume any responsibility for their content. Users of the FCPAC are responsible for obtaining all necessary rights and permissions from the appropriate rights holder for any use, reproduction and publication of these materials. Additionally, because the FCPAC has no control over third-party websites and materials, you acknowledge and agree that the FCPAC is not responsible for the availability of such external sites or resources, and does not endorse and is not responsible or liable for any content, advertising, products, or other materials on or available from such sites or resources. Your use of third-party websites, including all content provided on those sites, is subject to the terms of use, privacy policy, and other applicable terms of those websites.

Subject to the terms of this Terms of Service, with proper attribution, you may use the FCPAC for your personal, non-commercial research or analysis. Academic researchers who wish to access the underlying FCPAC data in Excel format should contact the FCPAC Content Manager at fcpac@law.stanford.edu. Scraping of the FCPAC website is not permitted, as set forth below.

By use of this website and/or your agreement to these Terms of Service at registration, you confirm that you accept and agree to comply with these terms of use and that you agree:

1. Not to reproduce, publish, distribute, sell, or modify the content of the FCPAC for use on another website, app, blog, product, extension, publication, or service, except with the prior express written consent of Stanford University and applicable rights holders of the Third-Party Materials.
2. Not to scrape the content of the FCPAC or use webcrawlers, spidering or other automated means to access, copy, index, process, and/or store any content made available on or through the FCPAC.
3. To abide by exclusionary protocols (e.g., Robots.txt, Automated Content Access Protocol (ACAP), etc.) that may be used by the FCPAC or the content owners whose material is indexed or stored by the FCPAC. You agree not to access parts of the FCPAC to which you are not authorized, or attempt to circumvent any restrictions imposed on your use or access of the FCPAC.
4. Not to aggregate or otherwise use the content of the FCPAC to create a site or a service that is similar to the FCPAC.
5. Not to use the FCPAC for any unlawful purpose. We reserve the right to terminate or restrict your access to the FCPAC if, in our opinion, your use of the FCPAC may violate any laws, regulations or rulings, infringe upon another person's rights, or violate these Terms of Service.
6. To respect our copyrights, trademarks, and other intellectual property rights as well as the intellectual property rights of others, including the applicable rights holders of the Third-Party Materials.
7. Not to falsely indicate the endorsement of the FCPAC or Stanford University of your project by any means.

Any unauthorized or prohibited use of any content may subject you to civil liability, criminal prosecution, or both, under applicable federal, state, local laws, or applicable foreign laws, rules, regulations, and treaties.

The FCPAC provides users the option to register and access the service through a unique username and password (the "User ID") that is for your personal, non-commercial use only. If you access the FCPAC with a User ID, you agree as follows:

As part of the registration process, which may be necessary to obtain access to the FCPAC, certain registration information may be provided to the FCPAC, Stanford University, and its authorized employees, contractors, vendors, and agents. You represent that your registration information is accurate and truthful. You shall promptly inform the FCPAC of any updates to your registration information in order to keep it true, accurate, and up to date. Each registration is for a single user only. The FCPAC reserves the right to deny creation of your account based on the FCPAC’s inability to verify the authenticity of your registration information.

The User ID may be used by you to gain access to the FCPAC only for so long as you are authorized to access and use the FCPAC in accordance with these Terms of Service.

Only you may access the FCPAC through the User ID.

You agree to treat the User ID as confidential and not to disclose such User ID, either directly or indirectly, to any person.

You shall not use a User ID that the FCPAC, in its sole discretion, deems offensive or inappropriate.

You are fully responsible for all usage and activity of the FCPAC, including, but not limited to, any use of the User ID.

Registration and the creation of a User ID are meant solely as a convenience for users and confer no copyright, trademark, or other rights to the user. The FCPAC reserves the right to terminate or suspend your access to the FCPAC at its discretion.

Disclaimer of Liability

The information included, indexed, stored or made available on the FCPAC and in the Email Notifications, whether provided by personnel employed by Stanford University or by third parties, is provided for the purposes outlined above only. The information is not intended as legal or any other professional advice and should not be considered as legal or any other professional advice.

In addition, neither Stanford University, nor any of its employees, agents, contractors, or affiliates, or third parties that provided services to Stanford University to create the FCPAC, including Sullivan & Cromwell LLP, warrants the timeliness, accuracy or completeness of the information or analyses displayed in the FCPAC, and we caution all users that inclusion of any information on this site or in the Email Notifications does not constitute an endorsement of the truthfulness or accuracy of that information. Use of the FCPAC and the Email Notifications is at your own risk.

You understand and agree that the FCPAC is provided "AS-IS" and that the FCPAC assumes no responsibility for the update, timeliness, deletion, mis-delivery, or failure to store any user communications or personalization settings. We do not guarantee that our site, or any content on it, will always be available or that access to it will be uninterrupted. To the fullest extent permitted by law, we disclaim all warranties and representations and other terms which may apply to our site or any content on it, whether express or implied.

We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with your use of, or inability to use, the FCPAC or the Email Notifications, or your use or reliance on any content on the FCPAC or in the Email Notifications.

Users agree to take responsibility for any use of the content on the FCPAC or in the Email Notifications and to hold Stanford University and its employees, agents, contractors, and affiliates harmless from any claims.

Copyright

Copyright © 2023. The Leland Stanford Junior University (Stanford University). All Rights Reserved. The information and graphics contained in this web site are copyrighted and may not be distributed, modified, or reproduced in whole or in part without the prior written permission of Stanford University. Copyright is not claimed as to any part of the original work prepared by Sullivan & Cromwell LLP, specifically the material found in the Sullivan & Cromwell Research & Reports section of the website. Sullivan & Cromwell LLP claims copyright of those materials. Copyright is not claimed as to any materials prepared by others, including the Third-Party Materials.

Documents are reproduced, stored, and displayed on the FCPAC with permission from Bloomberg Law.

We may amend these terms from time to time. Please check these terms regularly to ensure you understand the terms that apply at that time.

Except as otherwise modified by the terms set forth above, use of this site is also subject to the Terms of Use for use of Stanford’s websites.