Opinion Release 12-02-Travel for Foreign Governmental Officials Under the FCPA

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The Opinion Release set out the representations made by the Requestors to the DOJ which formed the basis for its decision. The Requestors stated that they would pay for the following:

• Business class airfare on international portions of flights for ministers, members of the legislature, and the director of the Orphanage Agency; coach airfare for international portions of flights for all other government officials; and coach airfare for domestic portions of flights for all government See more +

The Opinion Release set out the representations made by the Requestors to the DOJ which formed the basis for its decision. The Requestors stated that they would pay for the following:

• Business class airfare on international portions of flights for ministers, members of the legislature, and the director of the Orphanage Agency; coach airfare for international portions of flights for all other government officials; and coach airfare for domestic portions of flights for all government officials;

• Two or three nights hotel stay at a business-class hotel;

• Meals during the officials’ stays; and

• Transportation between agencies and local transportation.

The DOJ also noted the Requestors spending on meals and hotels would not exceed the rate set by the US General Services Administration for US government employees traveling within the US. The Requestors also made the following presentations which are consistent with prior DOJ guidance on travel, meals and entertainment.

• Entertainment - The entertainment will be of nominal cost and will involve families who have adopted children from the foreign country. In other words, a clear business purpose is involved.

• Selection - The Requestors did not select the foreign governmental officials to attend the trip but left that decision to the foreign government.

• No WAGS - The Requestors would only host the foreign governmental officials selected for the trip. There would be no spouses or family members brought along on this trip.

• Souvenirs - If there are any souvenirs presented to the visiting foreign officials, they will be of nominal value.

• Spending money - There will be no spending money provided to the foreign officials and they will not receive any stipends. There will be no additional monies paid to the visiting officials in any form.

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