Opinion Release 11-01: Lessons Learned on the Opinion Release Procedure

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However my “This Week in the FCPA” colleague, Howard Sklar, speaking in our Episode 12, suggested that there might be another aspect to this specific Opinion Release that I had not considered. While I had discussed the above points from the perspective of an outside counsel, in-house lawyer or compliance office who specialized in FCPA compliance work; the Opinion Release Procedure is designed so that any person or company may submit a query to the DOJ. Howard suggested that the Opinion Release Procedure could be utilized by a company which does not have either an in-house compliance practitioner or even a General Counsel. A question can be submitted to the DOJ as straight forwardly as with a one page document setting forth the information required under the Opinion Release Procedure.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox, Compliance Evangelist | Attorney Advertising

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