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Editor's Note: In last month's newsletter, the author shone a light on an issue that might be overlooked by some companies doing business overseas: the risk that a third party a business works with ' like a consultant, agent, broker or distributor ' will involve the company, perhaps unknowingly, in activities that could expose it to liability for violations of the the Foreign Corrupt Practices Act (FCPA), the government's primary weapon against bribery of foreign officials. That discussion concludes herein.
The DOJ's New Pilot FCPA Enforcement Plan
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The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
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