others have involved travel expenses and
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Company A’s officers and employees come into regular contact with
including officials in various ministries and state-owned entities. At a trade show
Company A invites a dozen current and prospective customers out for drinks
Company A won a long-term contract to supply goods and services to the state-owned Electricity
and employees of the Electricity Commission are subject to Foreign Country’s
properly recorded in a company’s books and records
Company A is providing training to the Electricity Commission’s employees and is hosting the Electricity
including ongoing monitoring and auditing
as the written laws and regulations of countries
and it is an affirmative defense where expenses
and the agent makes it. After receiving the
it could violate the FCPA’s books and records provision.
and to ensure the safety of its employees
184 and FCPA violations are no exception. Whether