FCPA Update: DOJ Opinion Procedure Releases Underscore That Payments to Officials Are Sometimes Permitted
GovCon & Trade
NOVEMBER 15, 2023
Two recent opinions released by the Department of Justice (DOJ) serve as a reminder that even under the strictly enforced Foreign Corrupt Practices Act (FCPA), payments to government officials are permissible in certain situations. Given how rarely DOJ issues such opinions and because each provides insight into DOJ’s current view of enforcement in particular scenarios, it is worth considering what can be learned from each opinion.
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