FCPA Opinion Procedure Release 08-03

FCPA Opinion Procedure Release 08-03 was a request from TRACE International, Inc. on paying expenses for journalists from China to attend a press conference being held by TRACE in Shanghai. Most of the media outlets are wholly-owned by the People’s Republic of China.

The opinion finds the stipend and expenses that TRACE intends to pay into the promotional expense affirmative defense because the expenses are “reasonable under the circumstances and directly relate to the promotion, demonstration, or explanation of [TRACE’s] products or services.”

Author: Doug Cornelius

You can find out more about Doug on the About Doug page

3 thoughts on “FCPA Opinion Procedure Release 08-03”

Leave a Reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.