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We Need Not Fear the Foreign: Safely Navigating Your Company through the F.C.P.A. Virginia Economic Development Partnership April 9, 2014 Andy Spalding.

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Presentation on theme: "We Need Not Fear the Foreign: Safely Navigating Your Company through the F.C.P.A. Virginia Economic Development Partnership April 9, 2014 Andy Spalding."— Presentation transcript:

1 We Need Not Fear the Foreign: Safely Navigating Your Company through the F.C.P.A. Virginia Economic Development Partnership April 9, 2014 Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

2 Scenario #1: A suitcase of cash for the Minister of Commerce Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

3 Scenario #2: Two Cases of Cognac and a Snowmobile for the Chief Customs Officer Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

4 Scenario #3: $200 to a Doctor at a State-Owned Hospital Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

5 Scenario #2: *Anything of Value *Foreign Official Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

6 Scenario #3: *No Materiality Threshold *Foreign Official Includes SOE Employees Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

7 Scenario #4: A Suitcase of Cash to the Minister of Commerce via a Foreign Lawyer Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

8 Scenario #4: *Payment to Any Person While Knowing it Will Be Used to Bribe Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

9 Scenario #5: “Make It Go Away” Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

10 Scenario #5: *Deliberate Ignorance/ Willful Blindness/ “Head in the Sand” “Aware of a High Probability” Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

11 Scenario #6: All Expenses-Paid Trip to U.S. for Foreign Government Client Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

12 Scenario #6: *Reasonable and Bona Fide Expenditures Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

13 Scenario #7: A Rogue Employee Defies Compliance Training Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

14 Scenario #7: *Respondeat Superior *Good Faith Compliance Defense *Declinations Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

15 COMPLIANCE Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog


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