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Richard L. Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Elizabeth K. Spahn Editor Emeritus

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor


FCPA Blog Daily News

Entries in Opinion Procedure Releases (12)

Wednesday
Mar022016

Bill Steinman: How to handle mandated per diems with foreign government customers

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. 

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Monday
Dec282015

Are DOJ opinion procedure releases headed for extinction? 

This could be the first year since 2005 when the DOJ won't issue any FCPA Opinion Procedure Releases.

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Friday
Nov212014

IKEA’s charitable giving in Russia and the FCPA (Part Five)

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.

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Sunday
Aug182013

JP Morgan China hirings trigger SEC probe

The SEC is investigating whether JP Morgan Chase violated the FCPA by hiring two children of Chinese officials to win business.

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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

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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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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Friday
Mar092012

Tom's Retort: DOJ Does Help Buyers

Tom Fox thinks Opinion Release 08-02 helped acquiring companies comply with the FCPA. He explains here.

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Thursday
Mar082012

Buyers Face An Impossible Choice

A few years ago, Halliburton -- no stranger to FCPA compliance problems -- was fighting to buy British firm Expro through a hostile takeover.

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Tuesday
Feb212012

Beyond Balance VII: Lost Opportunities of Successor Liability

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.

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Thursday
Jan052012

We Confess Our Love

There's no subtle way to say this: We love Shearman & Sterling's FCPA Digest.

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Friday
Nov182011

Do DOJ Opinions Harm American Companies?

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.'

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