The Department of Justice released the latest Opinion Procedure Release on the Foreign Corrupt Practices Act. The releases are great tool to help you figure out if a proposed corporate action could lead to an enforcement action. Anyone with an interest in the FCPA looks to the existing body of opinion releases as a way [...]
Tag Archives: FCPA Opinion Release
FCPA Release 10-03: Foreign Agents as Foreign Officials
The Department of Justice released its latest FCPA Opinion Release. The requesting company for this opinion release is stepping into a situation full of FCPA red flags. In the end, the DOJ opined that it would not bring an enforcement action based on the safeguards put in place by the company. The company is involved [...]
FCPA Opinion Procedure Release 10-02
A continuing quirk of the Foreign Corrupt Practices Act is the ability to ask the Department of Justice whether a particular set of facts would be a violation of the Act. Given all of the recent FCPA activity I expected there to be an uptick in Opinion Procedure Releases under the FCPA. So far that [...]
FCPA Opinion Procedure Release 10-01
The Department of Justice released its latest Opinion Procedure Release under the Foreign Corrupt Practices Act. It’s one of the quirks of the FCPA that you can ask the Department of Justice whether a particular situation would be a violation of the FCPA. This opinion is also quirky. The company requesting the opinion was in [...]
FCPA Opinion Procedure Release 09-01
The Department of Justice released its latest Opinion Procedure Release under the FCPA: 09-01 The Requestor designs and manufactures a specific type of medical device. The Requestor’s competitors already operate and sell their products to the government of a certain foreign country and the Requestor wants to enter that market. A senior government official laid [...]
TRACE and FCPA Opinion Procedure Release 08-03
The Summer 2008 newsletter from TRACE International provides some more background on FCPA Opinion Procedure Release 08-03. TRACE points out that this release was the first time that the DOJ has approved the payment of a specific dollar amount to government officials.
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 [...]
FCPA Opinion Procedure Release 93-01
FCPA Opinion Procedure Release 93-01 came from a company planning to enter into a joint venture partnership agreement to supply management services to a business venture owned and operated by a quasi-commercial entity, which entity is wholly owned and supervised by the government of a former Eastern bloc country. The requestor has represented that although [...]
FCPA Opinion Procedure Release 93-02
FCPA Opinion Procedure Release 93-02 came from a company which seeks to enter into a sales agreement with an entity in a foreign country. The entity is a government-owned business which holds a licence giving it the exclusive right to manufacture, sell, purchase, import, and export all defense equipment for that country’s armed forces. The [...]
FCPA Opinion Procedure Release 94-01
FCPA Opinion Procedure Release 94-01 came from a U.S. company and a foreign citizen. The American company seeks, through its subsidiary, to enter into a contract with a foreign national. The American company’s subsidiary is engaged in the manufacturing of products for use in clinical and hospital laboratories. Its manufacturing operations are located on real [...]
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