For the first time in FCPA history, a federal court judge, with the benefit of a detailed and complete overview of the FCPA’s extensive legislative history on the “foreign official” element, is being asked to rule on the DOJ’s interpretation that employees of alleged state-owned or state-controlled enterprises are “foreign officials” under the FCPA.
See here for the motion to dismiss in U.S. v. Stuart Carson, et al.
See here for my declaration.
Tuesday, February 22, 2011
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