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Practical Tips to Reduce FCPA Risk in Mergers and Acquisitions
document IMAGES-007-HOUSE_OVERSIGHT_022531.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

29 Practical Tips to Reduce FCPA Risk in Mergers and Acquisitions Companies pursuing mergers or acquisitions can take certain steps to identify and potentially reduce FCPA risks: M&A Opinion Procedure Release Requests: One option is to seek an opinion from DOJ in anticipation...

scrutiny than modest and routine gifts and entertainment
document IMAGES-007-HOUSE_OVERSIGHT_022561.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

59 scrutiny than modest and routine gifts and entertainment. Similarly, performing identical due diligence on all third- party agents, irrespective of risk factors, is often counter- productive, diverting attention and resources away from those third parties that pose the most s...

has taken steps to make certain that the code of conduct
document IMAGES-007-HOUSE_OVERSIGHT_022560.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

has taken steps to make certain that the code of conduct remains current and effective and whether a company has periodically reviewed and updated its code. Whether a company has policies and procedures that outline responsibilities for compliance within the company, detail prop...

In May of 2011, SEC entered into its first deferred
document IMAGES-007-HOUSE_OVERSIGHT_022579.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

77 In May of 2011, SEC entered into its first deferred prosecution agreement against a company for violating the FCPA.*® In that case, a global manufacturer of steel pipe products violated the FCPA by bribing Uzbekistan govern- ment officials during a bidding process to supply p...

Jeffrey Epstein: 1953-1969
document TEXT-001-HOUSE_OVERSIGHT_022058.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

CHAPTER 20 Jeffrey Epstein: 1953-1969 Jeffrey Epstein's mother, Paula, was the daughter of Max and Lena Stolofsky, who arrived in the United States as Lithua- nian refugees. Relatives on that side of the family who remained in the old country would all perish in the course of Ad...

company. No enforcement action was taken against the suc
document IMAGES-007-HOUSE_OVERSIGHT_022532.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

company. No enforcement action was taken against the suc- cessor, but the predecessor company pleaded guilty to one count of violating the FCPA and agreed to pay a $2 million fine.'” Later, four executives from the predecessor company were convicted of FCPA violations, three of w...

COLLABORATIVE INSIGHTS February 25, 2019
document IMAGES-008-HOUSE_OVERSIGHT_024918.txt Feb 25, 2019 House Oversight Committee — Epstein Estate Records (Nov 2025)

COWEN COLLABORATIVE INSIGHTS February 25, 2019 Equity Research Price Targets: Cowen and Company, LLC assigns price targets on all companies covered in equity research unless noted otherwise. The equity research price target for an issuer's stock represents the value that the ana...

You should rely only on the information contained in this Private Placement Memorandum (this
document IMAGES-007-HOUSE_OVERSIGHT_024434.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

You should rely only on the information contained in this Private Placement Memorandum (this “Memorandum”) or to which we have referred you. We have not authorized anyone to provide you with information that is different. This Memorandum may only be used where it is legal to sell...

Gather, Visualize, Analyze Public Opinion to make Intelligent Decisions
document TEXT-001-HOUSE_OVERSIGHT_028815.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

CONFIDENTIAL InsightsPod Gather, Visualize, Analyze Public Opinion to make Intelligent Decisions Business P' - Prepared September 2016 Contact Information Zubair Khan www.insightspod.com HOUSE OVERSIGHT 028815 InsightsPod Table of Contents Executive Summary..........................

How Come This Book?
document TEXT-001-HOUSE_OVERSIGHT_010912.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…m that handled nearly all my father’s business and little else. It was a big job. Lansing was smart, abrasive, and dead honest. He didn’t mind hurting people’s feelings. I was not immune. It didn’t matter. It wouldn’t have mattered to my father. What mattered was that Lansing kne...

company may experience significant adverse effects, which in turn could negatively affect the
document IMAGES-007-HOUSE_OVERSIGHT_024070.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

company may experience significant adverse effects, which in turn could negatively affect the performance of the Fund. Moreover, the current regulatory framework may change or additional regulations may arise at any stage during the product development phase of a portfolio compan...

Examples of Improper
document IMAGES-007-HOUSE_OVERSIGHT_022518.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

Examples of Improper Travel and Entertainment # a $12,000 birthday trip for a government decision- maker from Mexico that included visits to wineries and dinners # $10,000 spent on dinners, drinks, and entertainment for a government official "a trip to Italy for eight Iraqi go...