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Tales of crocodile tails under the FCPA

Tom Fox | October 25, 2016

The language of the Foreign Corrupt Practices Act is clear, as it prohibits providing anything of value to a foreign governmental official or employee of a state-owned enterprise. That phrase takes on new meaning when seen in the context of a recent New York Times article about corruption in China, which recited some of the exotic items that Chinese officials had received as bribes, including the well-known favorite: meat from the tail of a crocodile.

This description alone is worth the price of admission. “Zhang Jianjin, a former party secretary of a pharmaceutical company whose high living was paid for by businessmen seeking favors,” said he felt, “flattered to be treated to crocodile meat by a businessman.” Jianjin went on to detail, “He arranged for a crocodile tail, and it was a big one, more than three feet long.” It was laid out in a crescent shape...

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