FCPA Opinion Procedure Release 96-2

FCPA Opinion Procedure Release 96-2 came from a U.S. company engaged in the manufacture and sale of equipment used in commercial and military aircraft. The requestor wants to renew a contract with a state-owned enterprise of a foreign country, to assist the requestor by using its manufacturing expertise and experience in the foreign country to identify those entities that might be in the market for the parts and services currently available from the requestor. The requestor would provide these parts and services directly to the ultimate purchasers with the Enterprise receiving a commission based upon a percentage of net sales.

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