Top 3 FCPA Cases of 2010 Part III-HP and Red Flags

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This article concludes our series on what we believe to be the Top 3 Foreign Corrupt Practices Act (FCPA) cases in the first half of 2010. We have reviewed the facts surrounding each matter to come up with lessons that the FCPA compliance professional might use to assist putting forward a FCPA compliance ‘best practices’ program based upon the most recent information available. We previously explored the Gun Sting matter and (Ding Dong) Avon Calling and its China operations. Finally, we will review HP and its reported investigation for the alleged payments of bribes to secure a contract to sell computer hardware into Russia.

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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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