The u. S. Foreign corrupt practices act implications for international distributors

And if it blows up?

• And if it blows up?
• ▪ Consider voluntary self-reporting to DOJ of any violations
• ▪ Limits criminal & civil exposure, particularly when coupled with strong remedial action by company and cooperation
• ▪ Guidance on relevant factors in DOJ “Filip Memorandum” (August 2008): lists criteria for determination whether corporation deserves credit for cooperation

• And When Things Go Wrong

The information in this presentation is intended as general background information on legal issues arising in international business transactions in the U.S.. It is not to be considered as legal advice with regard to any particular business relationship or transaction. U.S. and foreign laws affecting international operations change often and information becomes rapidly outdated. Businesses considering international transactions or investments should consult legal counsel for advice on their particular issues.

• Contact Information

• The information in this presentation is intended as general background information on legal issues arising in international business transactions in the U.S.. It is not to be considered as legal advice with regard to any particular business relationship or transaction. U.S. and foreign laws affecting international operations change often and information becomes rapidly outdated. Businesses considering international transactions or investments should consult legal counsel for advice on their particular issues.
• Leslie K. L. Thiele, Esq. WHITEMAN OSTERMAN & HANNA LLP
• International Practice Group One Commerce Plaza
• Tel: [phone] Albany, New York 12260
• Fax: [phone] USA
• [e-mail]
• © 2009 Whiteman Osterman & Hanna LLP