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Instrumentality Anti-Bribery

A&O Shearman

DOJ Issues FCPA Opinion Procedure Approving Legitimate Payments To Government Instrumentalities

A&O Shearman on

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

Patterson Belknap Webb & Tyler LLP

FCPA Update: Eleventh Circuit Defines "Instrumentalities" of Foreign Governments

On May 16, 2014, the Eleventh Circuit issued its decision in United States v. Esquenazi, an important ruling that provides guidance as to what types of foreign entities may constitute “instrumentalities” of a foreign...more

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