DOJ: A Payment to Avoid Imminent Harm Is Not a Corrupt One Under the FCPA
On January 21, 2022, the Department of Justice (DOJ) released an Opinion letter, responding to an inquiry from a U.S.-based company regarding whether its payment of $175,000 in cash to “a third party purporting to act on behalf of” a foreign government’s Navy would violate the Foreign Corrupt Practices Act (FCPA).
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