• The Opinion Release Papers

  • By: Thomas Fox
  • Podcast

The Opinion Release Papers

By: Thomas Fox
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  • Summary

  • What are Opinion Releases under the FCPA? How do you submit something to the DOJ? If you have ever wondered about this process, this podcast series is for you as it focuses on Opinion Releases by the Department of Justice under the Foreign Corrupt Practices Act. I go through each Opinion Release, discuss the background facts and representations and key takeaways for the compliance practitioner.
    Thomas Fox
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Economics
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Episodes
  • Opinion Release Papers-11-01: Using the Opinion Release Procedure

    Opinion Release Papers-11-01: Using the Opinion Release Procedure
    Mar 8 2019
    The only Opinion Release of 2011 (11-01) may have left compliance practitioners initially scratching their heads. However, this collective head scratching is not because the Opinion Release is so difficult to understand and has no application to the everyday business of compliance, but for a polar opposite reason – the question posed to the Department of Justice (DOJ) is so straight-forward, and has been previously asked and answered, that it is difficult to understand how any first year compliance practitioner did not know the answer to it. Yet there is more than this facile analysis as to what may have been going on.  Learn more about your ad choices. Visit megaphone.fm/adchoices
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    10 mins
  • Opinion Release Papers-07-02-Business Entertainment for Foreign Officials

    Opinion Release Papers-07-02-Business Entertainment for Foreign Officials
    Mar 6 2019
    In the second Opinion Release of 2007, 07-02, the Department of Justice (DOJ) considered another scenario where a US company desired to pay for travel to the US of foreign officials and for some business entertainment while these persons were in the US. It had some additional facts beyond those from Opinion Release 07-01 which are important for a compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    10 mins
  • Opinion Release Papers-07-01-Travel for Foreign Officials

    Opinion Release Papers-07-01-Travel for Foreign Officials
    Mar 6 2019
    In 2007, the DOJ issued two Foreign Corrupt Practices Act (FCPA) Opinion Releases which offered guidance to companies considering whether to, and if so how to, incur travel and lodging expenses for government officials. Both Opinion Releases laid out the specific representations made to the DOJ, which led to the Department approving the travel to the US by the foreign governmental officials. These facts provided strong guidance to any company which seeks to bring such governmental officials to the US for a legitimate business purpose. In this podcast I discuss Opinion Release 07-01. In the next episode, I will take up 07-02. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    9 mins

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