The travel costs fall under the FCPA’s affirmative defense covering “reasonable and bona fide expenditures,” the Justice Department said in FCPA Opinion Release 12-02.
THE PAST AND FUTURE FOR CORPORATE PROSECUTIONS: Orrick partner Michael Madigan discusses his successful defense in 2006 of the former chairman of KPMG’s Tax Department, which led to reduced leverage for prosecutors in pursuing corporation prosecutions.
Mary Jacoby is the founder of Main Justice and Editor-in-Chief of Just Anti-Corruption.
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Dealing with complex issues of fraud, regulatory compliance and business disputes can detract from efforts to achi...
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