Company A invites a dozen current and prospective customers out for drinks
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bona fide expenditures made in connection with the promotion
including officials in various ministries and state-owned entities. At a trade show
Company A’s officers and employees come into regular contact with
such as Foreign Country. Company A’s stock is listed on a national U.S. stock
as an indirect way of corruptly influencing a foreign
000 birthday trip for a government decisionmaker
are unlikely to improperly influence an official
the payor must have corrupt intent—that is
others have involved travel expenses and
know generally that his conduct is unlawful.
he or she must act “willfully.” 81 Proof
the FCPA does not require that a corrupt
they can still be subject to jurisdiction under a traditional
and Intermediary is an “agent” of Company A. EuroCo and Intermediary are also subject to the FCPA’s
which entities fall within the FCPA’s jurisdiction?
and DOJ and SEC begin investigating whether the
and Company A and EuroCo win the contract. A few years later
including in a number of countries that have a high risk of corruption
a Delaware company with its principal place of business in New York