This week, we are pleased to have a guest post from Kevin Daly. Attorney Daly is a member of the firm’s Manufacturing Industry Group and also its Trade Compliance Team.
The Foreign Corrupt Practices Act (“FCPA”) prohibits paying or offering bribes to foreign officials to obtain business advantage. In some instances, the paying or offering of bribes prohibited by the FCPA may involve multiple electronic communications sent over time. A federal court in New Jersey recently considered the novel issue of whether multiple communications in furtherance of a single bribe can be charged as multiple offenses under the FCPA.
Continue Reading DOJ’s Latest FCPA Pressure Tactic: Charging Multiple Violations for Single Alleged Payment Scheme