When You Do Know What You Don’t (Want to) Know-Frederick Bourke and Conscious Avoidance

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The Legislative History of the Foreign Corrupt Practices Act (FCPA) makes clear that Congress intended that the so-called "head-in-the-sand" defense - also described as "conscious disregard", "willful blindness" or "deliberate ignorance" - should be covered so that company officials could not take refuge from the Act's prohibitions by their unwarranted obliviousness to any action (or inaction), language or other "signaling device" that should reasonably alert them of the "high probability" of an FCPA violation.

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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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