Skip to content

Compliance Building

Doug Cornelius on compliance for private equity real estate

Menu
  • Home
  • About
    • About
    • About Doug
    • About This Website
    • Why I Blog
    • Speaking Engagements
    • Contact
    • Publications
  • Archives
    • Topic Archive
    • Book Reviews
    • Most Popular
  • Subscribe
  • Disclaimers
    • Disclaimers
    • Policies and Procedures
    • Use of Site Content
    • Comments
    • FTC Disclosure
Menu

FCPA Opinion Procedure Release 94-01

Posted on October 22, 2008March 5, 2013 by Doug Cornelius
Print Friendly, PDF & Email

FCPA Opinion Procedure Release 94-01 came from a U.S. company and a foreign citizen. The American company seeks, through its subsidiary, to enter into a contract with a foreign national. The American company’s subsidiary is engaged in the manufacturing of products for use in clinical and hospital laboratories. Its manufacturing operations are located on real property which it acquired from a company that is a state-owned enterprise (the enterprise) now being transformed into a joint stock company.

The subsidiary wishes to enter into a contract with an individual who is the general director of the enterprise. The individual is a longtime resident of the area and has experience dealing with the local authorities and public utility service providers.

The American company’s foreign attorney has advised that under the nation’s law, the individual would not be regarded as either a government employee or a public official, the foreign attorney’s opinion is not dispositive, and we have considered the foreign individual to be a “foreign official’ under the statute.

Share this:

  • Print (Opens in new window) Print
  • Share on Facebook (Opens in new window) Facebook
  • Share on LinkedIn (Opens in new window) LinkedIn
  • Share on X (Opens in new window) X
  • Email a link to a friend (Opens in new window) Email

Leave a ReplyCancel reply

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

Search for Stuff

Recent Stories

  • Neither Admit Nor Deny To Be No Longer
  • What Will Form PF Look Like Next Year?
  • Is It a Chipset or Is It a Security?
  • When the Lawyer Is Breaking Bad
  • Will Investors Have an Appetite for Semi-Annual Reporting?
  • Special Forces Trading on Insider Knowledge
  • Prediction Markets and Compliance Programs
  • The One with the Line That Goes Straight Up and Right
  • The One with the Crypto Paying for a Mega-Shilling Package
  • The Performance of the SEC in 2025

Fight Cancer

Please support my Pan-Mass Challenge
Make a donation to fight cancer. donate.pmc.org/DC0176
pan-mass challenge badge

I am a lawyer, but I am not your lawyer. Since I’m a lawyer, this website may be considered attorney advertising under the ethical rules of certain jurisdictions. Please read my disclaimers page before taking any action. And then, don't take any action based on what I wrote.

Creative Commons logo with the text 'Some Rights Reserved' and three symbols representing attribution, non-commercial use, and share alike.

Compliance Building - by Doug Cornelius is licensed under a Creative Commons Attribution-Noncommercial 3.0 United States License.