Richard Craig Smith, Lista M. Cannon, Paul Sumilas and Paul Simon
September 26, 2011 view as PDF
In rare and helpful guidance for companies paying for the international travel of government officials, the U.S. Department of Justice announced it would not take any action under the U.S. Foreign Corrupt Practices Act against a U.S. company that proposed to pay certain expenses for two non-U.S. government officials traveling to the United States to learn more about a U.S. adoption service provider's services. Opinion Procedure Release No. 11-01 ("the Opinion"), was released on June 30, 2011, and is the first, and so far only, guidance issued in 2011.
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Richard Craig Smith
Lista M. Cannon