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Wining and Dining Foreign Officials
In December 2007, Lucent Technologies Inc. secured a non-prosecution agreement from the Department of Justice (DOJ) and settled an enforcement action with the SEC for conduct related to travel and entertainment expenses incurred on behalf of Chinese government officials and for the manner in which these expenses were booked. The Lucent settlement adds to a number of existing guideposts regarding permissible interactions with foreign officials under the Foreign Corrupt Practices Act (FCPA). This article examines the Lucent settlement together with prior FCPA enforcement activity related to travel and lodging, and offers some practical advice for compliance counsel.
Reasonable and Bona Fide Expenses
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