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Editorial: Anatomy of an FCPA Violation

Matt Kelly | November 1, 2009

So I may have violated the Foreign Corrupt Practices Act while I was on vacation recently.

Now, for the several readers of these pages who work at the Justice Department, let me state clearly that I’m not sure I violated the FCPA, and this isn’t an episode of self-disclosure. But while on vacation in South America, I had an interesting experience crossing the border into Bolivia that certainly felt like paying a bribe to me. Since FCPA compliance is such a vital part of chief compliance officers’ jobs these days, I wanted to recount the tale here as a from-the-front reminder of what your overseas employees encounter every day.

Our tale begins in the town of San Pedro de Atacama in Chile’s gorgeous northern desert. San Pedro borders the high-...

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