Other Related U.S. Laws OTHER RELATED U.S. LAWS Businesses and individuals should be aware that conduct that violates the FCPA‘s anti-bribery or accounting provisions may also violate other statutes or regulations. Moreover, payments to foreign government officials and intermedi- aries may violate these laws even if all of the elements of an FCPA violation are not present, Travel Act Act in 2009 where the relevant “unlawful activity” under The Travel Act, 18 US.C. § 1952, prohibits travel the Travel Act was an FCPA violation involving a bribery in interstate or foreign commerce or using the mail or any scheme in Azerbaijan.”” Also in 2009, a California com- facility in interstate or foreign commerce, with the intent pany that engaged in both bribery of foreign officials in vio- to distribute the proceeds of any unlawful activity or to lation of the FCPA and commercial bribery in violation of promote, manage, establish, or carry on any unlawful activ- California state law pleaded guilty to conspiracy to violate ity’? “Unlawful activity” includes violations of not only the FCPA and the Travel Act, among other charges.” the FCPA, but also state commercial bribery laws. Thus, bribery between private commercial enterprises may, in Money Laundering some circumstances, be covered by the Travel Act. Said dif- Many FCPA cases also involve violations of anti- ferently, if a company pays kickbacks to an employee of a money laundering statutes.” For example, two Florida private company who is not a foreign official, such private- executives of a Miami-based telecommunications company to-private bribery could possibly be charged under the were convicted of FCPA and money laundering conduct Travel Act. where they conducted financial transactions involving the DOJ has previously charged both individual and proceeds of specified unlawful activities—violations of the corporate defendants in FCPA cases with violations of FCPA, the criminal bribery laws of Haiti, and wire fraud— the T