FCPA Opinion Procedure Release 08-02 came at the request of Halliburton and its subsidiaries as they are looking to buy a UK well flow management company. They did not have enough time to complete the appropriate FCPA diligence on the target. Halliburton was concerned about inheriting FCPA liability as a result of its acquisition of the target company. There is a tight timeframe and a competing bid that prevents Halliburton from taking the steps that would ordinarily occur.
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