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Instrumentality Anti-Corruption

A&O Shearman

DOJ Issues FCPA Opinion Procedure Approving Legitimate Payments To Government Instrumentalities

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On August 14, 2020, the U.S. Department of Justice (“DOJ”) released its first Foreign Corrupt Practices Act (“FCPA”) Opinion (the “August 14 Opinion”) in six years, in response to a request from a multinational company...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for November 2014

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For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a...more

The Volkov Law Group

Knowing When to Fold — Arguing the FCPA’s Definition of “Foreign Official”

The Volkov Law Group on

With lots of fanfare, Esquenazi and Rodriguez, and the usual suspects filed a cert petition and briefs in support of the appeal from the 11th Circuit Court of Appeals’ decision affirming the lower court’s interpretation of...more

Dorsey & Whitney LLP

Anti-Corruption Digest

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Anti-Corruption Digest is an update distributed on a monthly basis by Dorsey & Whitney providing a summary of the latest developments in anti-corruption enforcement activity around the world. In This Issue: -...more

Stinson LLP

Eleventh Circuit Adopts Broad Definition of Government "Instrumentality" in Recent FCPA Case - Ruling Underscores the Need to...

Stinson LLP on

The Foreign Corrupt Practices Act (FCPA) makes it unlawful for a person or company to provide money or anything of value to any foreign official in order to obtain or retain business or to acquire an improper business...more

Morrison & Foerster LLP

Court of Appeals Hands Down Landmark FCPA Ruling Defining the Term “Instrumentality”

Federal appellate court decisions interpreting the Foreign Corrupt Practices Act (FCPA) are rare. Very rare. Indeed, in the statute’s 36-year history there have been barely more than a handful of appellate court decisions...more

Dechert LLP

In First Ruling by a Court of Appeals, Eleventh Circuit Adopts Broad Definition of “Foreign Instrumentality” under FCPA

Dechert LLP on

The Foreign Corrupt Practices Act (“FCPA”) prohibits bribing a “foreign official,” yet courts have rarely had the chance to weigh in on who exactly qualifies as a foreign official. Enforcement agencies have taken the position...more

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