FCPA Opinion Procedure Release 08-03 was a request from TRACE International, Inc. on paying expenses for journalists from China to attend a press conference being held by TRACE in Shanghai. Most of the media outlets are wholly-owned by the People’s Republic of China.
The opinion finds the stipend and expenses that TRACE intends to pay into the promotional expense affirmative defense because the expenses are “reasonable under the circumstances and directly relate to the promotion, demonstration, or explanation of [TRACE’s] products or services.”
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