FCPA Opinion Procedure Release 95-01 came from a U.S.-based energy company planning to acquire and operate a plant in a country in South Asia that lacks modern medical facilities in the region where the plant is located. A modern medical complex is presently under construction near the requestor’s future plant. Costs for the medical facility are projected to run to hundreds of millions of dollars. If the acquisition of the plant is completed, the requestor plans to donate $ 10 million in a public ceremony to the medical facility for construction and equipment costs.
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