Most FCPA Blog readers know that the FCPA contains an affirmative defense under which companies may incur expenses, such as meals or travel costs, on behalf of foreign government officials, so long as those expenses are reasonable and bona fide, and directly related to either showing off the company’s wares or executing or performing under a foreign government contract.
Entries in Opinion Procedure Releases (12)
This could be the first year since 2005 when the DOJ won't issue any FCPA Opinion Procedure Releases.
This is the fifth post in our series about IKEA’s charitable contributions in Russia in the 1990s and early 2000s. Today we’re looking at an event that at first glance doesn’t even appear to be a donation.
The SEC is investigating whether JP Morgan Chase violated the FCPA by hiring two children of Chinese officials to win business.
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.
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.
Tom Fox thinks Opinion Release 08-02 helped acquiring companies comply with the FCPA. He explains here.
A few years ago, Halliburton -- no stranger to FCPA compliance problems -- was fighting to buy British firm Expro through a hostile takeover.
In my last post, I examined a possible reform -- the expansion of personal jurisdiction -- and argued that although it is supported by anti-bribery advocates, it would actually serve the interests of the U.S. business community.
There's no subtle way to say this: We love Shearman & Sterling's FCPA Digest.
Earlier this month, the DOJ's Lanny Breuer said his agency expects to release detailed new guidance on FCPA enforcement sometime in 2012. Breuer said he hopes it will be 'a useful and transparent aid.'