Tagged: FCPA Opinion Letter

DOJ FCPA Opinion Letter Draws Lines Regarding “Corrupt Intent” and the “Business Purpose” Test

Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily harm.  While the situation may appear to be unique, it is a factual scenario that occurs more often than DOJ recognizes. In October 2021, a Requestor submitted an Opinion Letter application that...

Episode 223 — DOJ Issues FCPA Opinion Letter Drawing Lines on “Corrupt Intent” and “Business Purpose” Test

Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily harm.  While the situation may appear to be unique, it is a factual scenario that occurs more often than DOJ recognizes. In October 2021, a Requestor submitted an Opinion Letter application that...

FCPA Issues First Opinion Release in Six Years

FCPA Issues First Opinion Release in Six Years

Take it from me, if I recommend a stock pick to buy or sell – do the opposite.  In a great episode of Seinfeld, George Costanza adopted a new-life approach by doing the exact opposite of what he normally would do in a situation.  Here is the classic clip. In a podcast episode I recorded with Tom Fox, I made the “brilliant” point that DOJ...