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Understanding the FCPA - ACC.com

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<strong>FCPA</strong> Quiz<br />

HYPOTHETICAL 2:<br />

A U.S. technology <strong>com</strong>pany is seeking to secure <strong>the</strong> approval of <strong>the</strong> Chinese<br />

government to provide <strong>the</strong> country’s first wireless network. The Minister of<br />

Communications requests that a subordinate be permitted to visit <strong>the</strong> <strong>com</strong>pany’s<br />

headquarters in Sunnyvale, California to view a demonstration of <strong>the</strong> technology.<br />

QUESTION: How should <strong>the</strong> <strong>com</strong>pany respond to this request?<br />

1. True or False: It is illegal under <strong>the</strong> <strong>FCPA</strong> to provide travel expenses to a<br />

government official to view a product demonstration in <strong>the</strong> U.S.<br />

2. True or False: If a governmental official requests a visit to view a product<br />

demonstration in <strong>the</strong> U.S. and insists that <strong>com</strong>pany also pay for <strong>the</strong> travel expenses<br />

of his family so <strong>the</strong>y can visit Las Vegas after <strong>the</strong> demonstration, <strong>the</strong> payment of<br />

<strong>the</strong>se expenses would constitute an illegal bribe under <strong>the</strong> <strong>FCPA</strong>.<br />

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