Anti-corruption statutes reach conduct with limited domestic connection, which is why compliance programs are global.

Issuers and domestic concerns are covered for conduct anywhere, including acts entirely abroad by their officers, directors, employees and agents.

Foreign persons and entities are covered where they act in furtherance of a corrupt payment while in the territory, which has been construed broadly to include a wire or an email routed through the country.

Agents and intermediaries. Liability for a third party’s payments where the principal knew, which includes awareness of a high probability of the conduct and conscious avoidance.

Parent liability for subsidiaries through agency, through direct participation, and through the books and records provisions where the subsidiary’s results are consolidated.

Conspiracy and aiding and abetting extending reach to parties not otherwise covered, a theory that has been narrowed by some decisions.

Successor liability for acquired conduct, mitigated by pre-acquisition diligence and prompt post-acquisition remediation and disclosure, which enforcement policy expressly rewards.

Other regimes. Several countries have statutes with their own broad reach, including corporate offenses of failing to prevent bribery with an adequate procedures defense, so multinationals face overlapping obligations.