The hospitality industry is particularly susceptible to FCPA risk. Hospitality companies often operate in corruption prone areas, such as Asia, India, Latin America and the Caribbean. Furthermore, by the very nature of their business, hospitality companies must interact with the governments in these areas to obtain a panoply of licenses, permits, approvals and services. Given these frequent dealings with foreign government officials in some of the most difficult places to operate in the world, not to mention the recent enforcement activity against an industry member, it would not be surprising if the hospitality industry found itself following the pharmaceutical, defense, logistics and financial services industries as the latest group to face an industry-wide probe from DOJ and the SEC.
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