FCPA Opinion Procedure Release 08-03


FCPA Opinion Procedure Release 08-03 was a request from TRACE International, Inc. on paying expenses for journalists from China to attend a press conference being held by TRACE in Shanghai. Most of the media outlets are wholly-owned by the People’s Republic of China.

The opinion finds the stipend and expenses that TRACE intends to pay into the promotional expense affirmative defense because the expenses are “reasonable under the circumstances and directly relate to the promotion, demonstration, or explanation of [TRACE's] products or services.”

The Opinion Procedure Release process is a fairly unique process under the Foreign Corrupt Practices Act.

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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.

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