US EditionUnited States: America first — A recasting of DOJ FCPA enforcement policy in the name of national security
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United States: America first — A recasting of DOJ FCPA enforcement policy in the name of national security
In brief Foreign Corrupt Practices Act (FCPA) enforcement still exists, but it’s unclear where the lines will be drawn. Prima facie exposure to FCPA enforcement will evidently no longer be based solely on evidence that a US or other company or person simply bribed a foreign official. Now a more subjective approach will be implemented, which makes it more difficult to calibrate enforcement risk. Bribes involving Transnational Criminal Organizatio…
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