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Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

We Need Not Fear the Foreign: Safely Navigating Your Company through the F.C.P.A. Virginia Economic Development Partnership April 9, 2014. Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog. Scenario #1: A suitcase of cash for the Minister of Commerce.

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Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

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  1. We Need Not Fear the Foreign: Safely Navigating Your Company through the F.C.P.A.Virginia Economic Development PartnershipApril 9, 2014 Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  2. Scenario #1:A suitcase of cash for the Minister of Commerce Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  3. Scenario #2:Two Cases of Cognac and a Snowmobilefor the Chief Customs Officer Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  4. Scenario #3:$200 to a Doctorat a State-Owned Hospital Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  5. Scenario #2:*Anything of Value*Foreign Official Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  6. Scenario #3:*No Materiality Threshold*Foreign Official Includes SOE Employees Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  7. Scenario #4:A Suitcase of Cash to the Minister of Commerce via a Foreign Lawyer Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  8. Scenario #4:*Payment to Any Person While Knowing it Will Be Used to Bribe Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  9. Scenario #5:“Make It Go Away” Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  10. Scenario #5:*Deliberate Ignorance/Willful Blindness/“Head in the Sand”“Aware of a High Probability” Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  11. Scenario #6:All Expenses-Paid Trip to U.S. for Foreign Government Client Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  12. Scenario #6:*Reasonable and Bona Fide Expenditures Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  13. Scenario #7:A Rogue Employee Defies Compliance Training Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  14. Scenario #7:*Respondeat Superior*Good Faith Compliance Defense*Declinations Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

  15. COMPLIANCE Andy Spalding University of Richmond School of Law Senior Editor, The FCPA Blog

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