The Department of Justice issued its first FCPA opinion release of the year, declining to take enforcement action against a U.S. financial services company and investment bank that is the majority shareholder of a foreign financial services company. See U.S. Dep’t of Justice, FCPA Opinion Procedure Release No. 14-01(Mar. 17, 2014).  Here, a minority shareholder in the foreign financial services company was appointed to a senior position in his country’s central monetary and banking agency. The U.S. financial services company proposed to buy his shares, at a value determined by a third-party global accounting firm, and the foreign official agreed to strict recusal rules prohibiting him from participating in or influencing his agency’s decisions regarding the financial company of which he formerly was a shareholder until after the completion of the buyout. He also agreed to recuse himself from any matter between his agency and his former company that was under negotiation, proposed, or anticipated at the time of, or prior to, the buyout. The DOJ determined that under these circumstances, there was no corrupt intent.