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FCPA Blog Daily News

Entries in Foreign Official (149)


DOJ names permanent chief of FCPA Unit

The DOJ announced that Daniel Kahn became Chief of the FCPA Unit, effective June 1.

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Hiring foreign officials: How do you justify it?

One of the threshold questions for a company considering the engagement of a government official is whether the engagement is needed for legitimate purposes. If the company cannot articulate an adequate and appropriate business justification, there is a risk that the engagement may be sought or undertaken for a corrupt purpose.

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Practice Alert: Engaging foreign officials as consultants and speakers

Companies operating in emerging markets sometimes retain qualified government officials to provide services such as consulting or speaking. In some circumstances, particularly in developing markets, these services are necessary and can serve a company’s legitimate business needs.

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Why some doctors at China state-owned hospitals may not be ‘foreign officials’

A recent scandal at a major Chinese public hospital revealed that many of the public hospitals across the country outsource their medical services to private companies and employ doctors as independent contractors.  That could raise doubts about some public hospital doctors in China being "foreign officials" under the FCPA.

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Bill Steinman: Let's talk about per diems, without the shouting

Per diems. We in the FCPA bar love to hate them, and with good reason. Who likes the idea of giving cash to foreign officials? If there’s anything that should rankle the anti-corruption specialist, this is it. 

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Compliance alert: India Supremes say private bankers are ‘public servants’

The Indian Supreme Court has expanded the definition of public servant in a decision that has implications for not only the banking system but potentially the country’s broader struggle against corruption.

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Sundar Narayanan: Is your next compliance problem at a toll booth in Delhi?

Delhi recently started enforcing new traffic regulations to reduce pollution levels. In October 2015, the city -- properly the National Capital Territory, where 10 million people live -- imposed a Green Tax on vehicles. 

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Russian nuke official, two others plead guilty in FCPA-related case

A Russian official living in Maryland pleaded guilty Monday to conspiracy to commit money laundering for taking over $2 million in bribes in exchange for transport contracts with the Russian state-owned nuclear energy corporation.

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How to hire a princeling: Six rules anyone can follow

Last week BNY Mellon agreed to pay the SEC $14.8 million to settle charges that it violated the Foreign Corrupt Practices Act by awarding student internships to kids of officials connected with a sovereign wealth fund in the Middle East.

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Brazil's Electrobras hires Hogan Lovells for bribery investigation

Dear FCPA Blog,

You may have seen this announcement in an SEC filing on June 10 by the Brazilian-owned electric company Centrais Eletricas Brasileiras SA –Electrobras:

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A free press exposes graft and restrains greed

The FCPA Blog reminds itself often that freedom of the press and free speech are the most powerful weapons against corruption. As Louis Brandeis said, sunlight is the best disinfectant.

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The business community can reduce corruption risk by improving regulatory quality

Contacts with a government in the course of conducting every day business raise the risk of providing something of value to a foreign official. This risk can be minimized via appropriate controls and efforts on the part of industry groups, through collective action, to improve regulatory quality.

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