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Canadian Foreign Anti-Bribery Law


Lawyer Sheldon Freeman, Kirk Rauliuk
Area Corporate Finance and Securities, Asia Practice, White Collar Risk Management and Investigations


Canada, like other jurisdictions, has had in place for several years anti-bribery and corruption legislation – the Corruption of Foreign Public Officials Act (the “CFPOA”) – that prohibits payments made (or offered to be made) to foreign officials for the purposes of obtaining a commercial advantage.

While Canadian authorities have been less active than those in the United States and the United Kingdom in the enforcement of foreign anti-bribery legislation, high profile guilty pleas, the highly publicized laying of CFPOA charges against a prominent Canadian engineering company earlier this year and the more than 30 potential CFPOA violations the Royal Canadian Mounted Police (the “RCMP”) is reportedly investigating suggest that this may be changing.

The summary below provides an overview of some of the key legal considerations relevant to Canada’s foreign anti-bribery law and the Canadian federal government’s “Integrity Framework”, which precludes those convicted of CFPOA offences (or offences under equivalent legislation in other countries) from bidding on contracts with the Canadian federal government.

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