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Entries in Foreign Official (139)

Wednesday
Nov282012

FCPA opinions get a face lift

In the recently released FCPA guidance, the DOJ devoted an entire chapter to its FCPA opinions procedure releases -- when to ask for one, how to make a request, and how to use the answer.

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Monday
Nov192012

DOJ to industry: Don't sweat the small stuff

Both the guidance and recent remarks by officials make clear that, although the FCPA has no value threshold, the government is not interested in bringing cases over de minimis payments to foreign officials.

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Monday
Nov192012

New FCPA guidance: no sea change but a helpful enforcement summary

Last week, the DOJ and SEC issued their long-anticipated Resource Guide regarding the agencies’ FCPA enforcement. Over a year in the drafting, the 120-page Guide addresses, among other things, (1) the definition of a foreign official, (2) gifts and entertainment, and (3) the “hallmarks” of an effective corporate compliance program. 

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Thursday
Nov152012

Hitting the highpoints with the DOJ

Gifts, travel and entertainment, foreign officials, successor liability, and effective compliance programs.

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Friday
Oct262012

New DOJ opinion on promotional expenses by non-profit adoption agencies

The DOJ's second Opinion Procedure Release this year approved a plan by 19 non-profit adoption agencies to bring foreign officials to the United States to meet the staff at the agencies and families who have already adopted kids from the officials' country.

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Monday
Sep242012

Tyco in $26 million settlement with DOJ and SEC 

Tyco International Ltd. agreed on Monday to pay criminal and civil penalties totaling more than $26 million to resolve Foreign Corrupt Practices Act violations.

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Tuesday
Sep042012

Autumnal Adventures to Unchartered Corners

I’ve tried to map out some unfamiliar ways to think about FCPA reform. See these proposals as you might an old map -- exploratory, perhaps imprecise, still incomplete -- but meant to excite the human spirit.

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Wednesday
Aug222012

DOJ Answers Esquenazi and Rodriguez

The appeal by Carlos Rodriguez and Joel Esquenazi of their FCPA convictions is now with the 11th Circuit Court of Appeals.

As Mike Koehler noted in his post today (and in prior coverage), 'this is a historic appeal, the first time in the FCPA’s history that “foreign official” will be squarely before an appellate court.'

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Thursday
Aug092012

The Hunt For Public International Organizations

What are public international organizations? Philip Fitzgerald dives deep for an answer.

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Tuesday
Jul172012

Tell Us: Are NGOs Instrumentalities?

The academic jury seemed intrigued by a related issue: What about officials of NGOs, who are not "foreign public officials" under the FCPA or other international texts?

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