Page 169 - CFF

FCPA investigations (continued)

FCPA requirements (continued)

• Corrupt payments or corrupt intent to make payments is forbidden

– Gifts or payments to foreign officials to obtain or keep business whether or not the bribe
produces actual business

– Improper payments or gifts through third parties made at the behest of foreign officials,
including charitable and political contributions

– The definition of foreign officials is very broad

– Public officials
– Private individuals affiliated with state-run organizations

– Local laws can exempt payments

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