including liability for unlawful payments
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In the Matter of United Industrial Corp.
Exchange Act Release No. 61325 ( Jan. 11
was charged with civil violations of the
which eventually discovered these payments
582 F. Supp. 2d at 540 (citing S. Rep. No. 95-114
the Fifth Circuit emphasized this precise point
or the expeditious performance of similar duties of an essentially
at 53. Responding to criticism that the statutory language “does not
payments of this kind fall outside the scope of the
1983) (declining to take enforcement action against
available at http://www.justice.gov/criminal/
available at http://www.justice.gov/criminal/fraud/fcpa/
available at http://www.justice.gov/criminal/fraud/fcpa/
available at http://www.justice.gov/criminal/fraud/fcpa/
government-affiliated journalists attending press
available at http://www.justice.gov/criminal/
the court found that a provision under Azeri law that
available at http://www.sec.gov/litigation/complaints/2010/
available at http://www.justice.gov/criminal/fraud/fcpa/