- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Kyle Brasseur2023-09-01T18:37:00
A Foreign Corrupt Practices Act (FCPA) review published by the Department of Justice (DOJ) last month offers further clarity around when the agency would determine expenses paid on behalf of a foreign official to be deemed “reasonable and bona fide.”
The opinion procedure release from Aug. 14—the first posted by the DOJ since January 2022—came in response to a request from a child welfare agency regarding whether its proposed payments on behalf of two foreign government officials visiting the United States to complete their post-adoption supervision requirements would violate the anti-bribery provisions of the FCPA.
Among the details of the request:
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