Tagged: business purpose

DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose

DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose

The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious).  The reasons for this may be a question of timing elements in the pipeline of cases.  What is clear is that pushing through an enforcement action and settlement requires increased coordination with a growing number of international partners.  That may be part of the explanation. In this environment,...