The Justice Department has released new guidance to help companies understand how they can host foreign officials without running afoul of the anti-bribery Foreign Corrupt Practices Act.
The guidance is in the form of two “opinion procedure releases” that address the propriety of promotional expenditures such as travel, gifts, and entertainment associated with hosting foreign government officials in the United States. A legal bulletin from the law firm Wilkie, Farr & Gallagher describes the opinions as “helpful guidance on what will clearly constitute acceptable expenditures” under the FCPA’s provisions allowing some promotional outlays.
