On Permits …

FCPA Professor – The root cause of many Foreign Corrupt Practices Act enforcement actions is a foreign law or regulation that forces a company (through an employee or agent) into a relationship with a “foreign official.” This root cause analysis is often fairly straightforward: foreign law or regulation often creates bureaucracy; bureaucracy creates points of contact with foreign officials; these points of contact create discretion; and discretion creates the opportunity for a foreign official to misuse their position by making bribe demands.

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