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The Enforcement Officials Speak

Over at the wrageblog (see here), Alexandra Wrage, President of Trace International Inc., a leading non-profit membership association focused on anti-bribery compliance, has a good summary post of comments made by Mark Mendelsohn (DOJ’s top FCPA prosecutor) and others at a recent FCPA conference.

Given that the enforcement agencies’ untested and unchallenged interpretation of the “foreign official” element is one of my favorite FCPA issues, I was happy to see that Mendelsohn, in response to a question, apparently acknowledged that there can be difficult assessments of who qualifies as a “foreign official” under the FCPA.

Looks like FCPA trials are over for the year, but I’m guessing that there will be forthcoming appeals from the three FCPA verdicts reached this summer.

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