- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Jaclyn Jaeger2022-02-03T18:15:00
A payment by a U.S.-based company to a third-party intermediary under circumstances that placed an employee’s life and well-being at “significant risk” would not trigger enforcement under the anti-bribery provisions of the FCPA, the Department of Justice stated in an opinion procedure.
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