The purpose of the Foreign Corrupt Policies Act of 1977 was to make it unlawful for certain people and businesses to pay foreign government officials in return for assistance in obtaining business. The anti-bribery provisions prohibit the willful use of mail or other means of commerce to offer or pay money or anything of value to anyone who will directly or indirectly pass this to a goring official to influence to secure an unlawful advantage. This act also requires securities listed in the USA to meet certain accounting provisions . The current event that I choose occurred on December 26, 2018 when the SEC charged Polycom with violating the Foreign Corrupt Policies Act. Polycom is a California based communications provider. The company agreed to pay more than $16 million to settle charges in connection with its Chinese subsidiary making improper payments to government officials. From 2006-2014 the Chinese subsidiary used distributors and resellers to make payments to the Chinese government official in exchange for assistance in securing business deals for Polycom products. Polymer sold products to the distributers and resellers at discounted prices with the understanding that they were to make cash payments to the officials whom exercise influence over customer purchases. Polycom recorded false justifications in the records for the discounts. The SEC claimed Polycom failed to maintain a sufficient system of internal accounting controls and lacked an efficient anti-corruption compliance program in China.

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