In Opinion Release 10-01, the Department of Justice considered a request by a United States company that entered into a contract with a U.S. government agency to perform work in a foreign country. Pursuant to the terms of that contract, the U.S. company hired a foreign official to manage a facility being built abroad. The DOJ determined that it would not bring an enforcement action against the U.S. company because the hiring was pursuant to an agreement between the U.S. government and the foreign country, and the official (appointed by the foreign country) has no influence over matters affecting the company. The company was thus bound by its contract with the U.S. government (which had entered into the relevant agreement with the foreign country) to hire the individual/foreign official. See Opinion 10-01, available at http://www.justice.gov/criminal/fraud/fcpa/ opinion/2010/1001.pdf.