Wining and Dining Foreign Officials: What's OK and What's a Crime

In December 2007, Lucent Technologies Inc. secured a non-prosecution agreement from the Department of Justice and settled an enforcement action with the SEC for conduct related to travel and entertainment expenses incurred on behalf of Chinese government officials and for the manner in which these expenses were booked. The Lucent settlement adds to a number of existing guideposts regarding permissible interactions with foreign officials under the Foreign Corrupt Practices Act. This article examines the Lucent settlement, prior FCPA enforcement activity related to travel and lodging, and offers some practical advice for compliance counsel.

23 minute read March 27, 2008 at 03:36 PM
By
David S. Krakoff and James T. Parkinson
Wining and Dining Foreign Officials: What's OK and What's a Crime

In December 2007, Lucent Technologies Inc. secured a non-prosecution agreement from the Department of Justice (DOJ) and settled an enforcement action with the SEC for conduct related to travel and entertainment expenses incurred on behalf of Chinese government officials and for the manner in which these expenses were booked.

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