A payment by a U.S.-based company to a third-party intermediary under circumstances that placed an employee’s life and well-being at “significant risk” would not trigger enforcement under the anti-bribery provisions of the Foreign Corrupt Practices Act, the Department of Justice stated in its first FCPA opinion procedure in two years.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...