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Friday Roundup

Roundup

Not true, DOJ appeal, scrutiny alert, and monitor extended. It’s all here in the Friday roundup.

Not True

In this recent Trace International sponsored podcast about the 2014 Esquenazi decision, Bill Steinmen (Senior Editor at the FCPA Blog) asserts that the FCPA’s “legislative history doesn’t really shed any light” on the meaning of “instrumentality” in the FCPA.

Not true.

There is much information in the FCPA’s legislative history relevant to the issue of whether Congress intended the phrase “instrumentality” in the “foreign official” definition to cover state-owned or state-controlled enterprises (“SOEs”).

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Potpourri

Potpourri

Scrutiny Alerts

CHS Inc., an agricultural cooperative, disclosed:

“In the fourth quarter of fiscal 2018, we contacted the U.S. Department of Justice and SEC to voluntarily self-disclose potential violations of the FCPA in connection with a small number of reimbursements the Company made to Mexican customs agents in the 2014-2015 time period for payments the customs agents made to Mexican customs officials in connection with inspections of grain crossing the U.S.-Mexican border by railcar. We are fully cooperating with the government, including with the assistance of legal counsel, which assistance includes investigating other areas of potential interest to the government. We are unable at this time to predict when our or the government agencies’ review of these matters will be completed or what regulatory or other outcomes may result.”

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