Compliance Building

FCPA Opinion Procedure Release 93-02 came from a company which seeks to enter into a sales agreement with an entity in a foreign country. The entity is a government-owned business which holds a licence giving it the exclusive right to manufacture, sell, purchase, import, and export all defense equipment for that country’s armed forces. The … Read more »

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 … Read more »

FCPA Opinion Procedure Release 95-01 came from a U.S.-based energy company planning to acquire and operate a plant in a country in South Asia that lacks modern medical facilities in the region where the plant is located. A modern medical complex is presently under construction near the requestor’s future plant. Costs for the medical facility … Read more »

FCPA Opinion Procedure Release 95-02 came from two U.S. companies planning to enter into transactions in a foreign country. One company has offset obligations. The other company generates offset credits through new subsidiary. The majority of investors in the new subsidiary will be foreign government officials. Among other agreements with the investors/government officials: The shareholders … Read more »

FCPA Opinion Procedure Release 96-01 came from a non-profit environmental group proposing to sponsor and provide funding for up to ten government representatives from regional nations to attend training courses in the United States. The requestor would pay for round-trip air fare to a U.S. city, transportation by van to and from the airport, hotel … Read more »

FCPA Opinion Procedure Release 96-2 came from a U.S. company engaged in the manufacture and sale of equipment used in commercial and military aircraft. The requestor wants to renew a contract with a state-owned enterprise of a foreign country, to assist the requestor by using its manufacturing expertise and experience in the foreign country to … Read more »

FCPA Opinion Procedure Release 97-01 came from a U.S. company whose wholly owned subsidiary is submitting a bid to a foreign government-owned entity to sell and service certain high technology equipment. In connection with its bid, the requestor has entered into a Representative Agreement with a privately held company Representative in the same foreign country. … Read more »

FCPA Opinion Procedure Release 1997-02 came from a U.S. utility constructing a plant in Asia. The requestor plans to donate $100,000 to a proposed school construction project. The donation would be made directly to the government entity responsible for the construction and supply of the proposed elementary school. As the requestor’s donation will be made … Read more »

FCPA Opinion Procedure Release 1998-2 came from a U.S. company submitting a bid to a foreign government-owned entity to sell and service a certain military training program. In connection with its bid, the Requestor intends to enter into several agreements with a privately-held company in the same foreign country. These agreements include a Settlement Agreement … Read more »

FCPA Opinion Procedure Release 2000 – 01 came from a U.S. law firm and a foreign partner of Requestor, (1) who has been appointed to a high-ranking position in the government of a foreign country. The Foreign Government Official has taken a leave of absence from the law firm who proposes to make some payments … Read more »