FCPA Review Procedure Release 81-02

FCPA Review Procedure Release 81-02 came from the Iowa Beef Packers, Inc. who wanted to send promotional samples to the Soviet Ministry of Foreign Trade, the Soviet government agency responsible for procurement of such products.

The total amount of the samples which the company intends to furnish to these officials is approximately 700 pounds of beef, with an estimated total value of less than $2,000. Individual sample packages will not exceed $250 in value. IBP estimates that prospective sales of packaged beef products to the Soviet government will be in minimum amounts of 40,000 pounds each.

The company has represented that the sample products to be presented to MVT officials are intended as items for their inspection, testing and sampling, and to make these officials aware of the quality of the company’s products. IBP also represents that the sample products are not intended for the individual use of the MVT officials, but will be provided to them in their capacity as representatives of the government agency responsible for purchasing the company’s products. Finally, the Soviet government has been informed that the company intends to furnish sample products to the MVT officials.

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  1. FCPA Opinion Procedure Release 09-01 | Compliance Building - August 7, 2009

    […] obvious comparison is to the Iowa Beef Packers request to send free samples addressed in FCPA Review Procedure Release 81-02. But that only involved 700 pounds of beef, with an estimated total value of less than […]