In its first “Opinion Procedure Release” of 2014, the U.S. Department of Justice responded to a request from a “United States financial services company and investment bank” regarding the valuation of shares held by a minority shareholder in a foreign subsidiary, who was recently appointed to a senior government position in the country, making him a “foreign official” within the meaning of the FCPA. The DOJ release approved the company’s plan to abandon the valuation process in the parties’ 2007 shareholder  agreement, which yielded a negative value for the shares due to unforeseen losses in the 2008 financial crisis, and instead employ “a leading, highly regarded, global accounting firm to determine the shares’ value.” The DOJ cited the lack of corrupt intent and commented that the purpose of the payment to the foreign official was “to sever the parties’ existing financial relationship, which began before the  foreign  shareholder held an official position. Doing so would also avoid what would otherwise be an ongoing conflict of interest.