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Understanding the FCPA - ACC.com

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<strong>FCPA</strong> Anti-Bribery Provisions – Elements<br />

The <strong>FCPA</strong>’s anti-bribery provisions prohibit –<br />

any “knowing” act in support of<br />

a payment, an offer to pay or an authorization<br />

to pay<br />

money or ―anything of value‖<br />

directly or indirectly (e.g., through any agent, consultant, or<br />

third-party)<br />

to any foreign government official, foreign political party or<br />

party official, foreign political candidate, or officers of a public<br />

international organization (―foreign officials‖); or<br />

to a third person “knowing” it will be passed on to a<br />

foreign official<br />

7

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