The affirmative defense for promotional expenses has always been a riddle, which explains why it appears so often among the Justice Department’s Opinion Procedure Releases, including both Releases so far this year.… Continue Reading
Panalpina’s cooperation with the U.S. Department of Justice appears to be in full swing. For starters, it is exiting the Nigeria logistics and freight forwarding market for all oil and gas services customers, at least a dozen of which have been contacted by the DOJ about Panalpina’s customs clearance practices in Nigeria and other countries.… Continue Reading
In its second Opinion Procedure Release of 2007, the Department of Justice again looked at promotional expenses. An affirmative defense in the U.S. Foreign Corrupt Practices Act allows payment or reimbursement of expenses of foreign officials that are directly related to “the promotion, demonstration, or explanation of products or services.”… Continue Reading
Instead of our regular post today, these familiar and fitting words:
No man is an Island, entire of itself; every man is a piece of the Continent, a part of the main; if a clod be washed away by the sea, Europe is the less, as well as if a promontory were, as well as if a manor of thy friends or of thine own were; any man’s death diminishes me, because I am involved in Mankind; And therefore never send to know for whom the bell tolls; It tolls for thee.… Continue Reading
The FCPA Blog is produced and edited by attorneys of Cassin Law LLC. The firm helps clients comply with United States laws, including the Foreign Corrupt Practices Act.
The information in The FCPA Blog is intended for public discussion and educational purposes only.… Continue Reading
Perhaps the biggest, although not yet the loudest, international corruption story involves Siemens AG, the German electronics and electrical engineering giant. Siemens says it has identified “a multitude of payments made in connection with [consulting agreements] for which we have not yet been able either to establish a valid business purpose or to clearly identify the recipient.… Continue Reading