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Freedom from Corruption_ the New Human Right_ …

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We Need Not Fear the Foreign:Safely Navigating Your Company through the F.C.P.A.Virginia Economic DevelopmentPartnershipApril9, 2014
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog
Scenario #1:A suitcase of cash for theMinister of Commerce
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog
Scenario #2:Two Cases of Cognacand a Snowmobilefor the Chief Customs Officer
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog
Scenario #3:$200 to a Doctorat a State-Owned Hospital
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog
Scenario #2:*Anything of Value*Foreign Official
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog
Scenario #3:*No Materiality Threshold*Foreign Official Includes SOE Employees
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

Scenario #4:A Suitcase of Cash to the Minister of Commerce via a Foreign Lawyer
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

Scenario #4:*Payment to Any PersonWhileKnowingit Will Be Used to Bribe
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

Scenario #5:“Make It Go Away”
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

Scenario #5:*Deliberate Ignorance/Willful Blindness/“Head in the Sand”“Aware of a High Probability”
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

Scenario #6:All Expenses-Paid Trip to U.S. forForeign Government Client
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

Scenario #6:*Reasonable and Bona Fide Expenditures
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

Scenario #7:A Rogue Employee DefiesCompliance Training
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

Scenario #7:*RespondeatSuperior*Good Faith Compliance Defense*Declinations
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

COMPLIANCE
Andy SpaldingUniversity of Richmond School of LawSenior Editor, The FCPA Blog

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Freedom from Corruption_ the New Human Right_ …