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Controversy continues over interpretation of "foreign official"

  • Edwards Wildman Palmer LLP
  • -
  • USA
  • -
  • October 12 2011

The U.S. Justice Department continues to walk back from its earlier articulated position in an ongoing litigation matter that to be convicted under the U.S. FCPA anti-bribery provisions, an individual must be aware that the recipient of any bribe is an official of a foreign government