In this episode of the FCPA Opinion Papers, we consider Opinion Release 14-02 which lays out the process to invoke the safe harbor around mergers and acquisitions (M&A) context. The issue for consideration is if a U.S. company purchases a company not previously subject to the FCPA and the target had engaged in bribery and corruption, would the US company be liable for the target's prior acts under the FCPA?
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