Search

Editors

Harry Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Richard L. Cassin Editor at Large

Elizabeth K. Spahn Editor Emeritus 

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor


FCPA Blog Daily News

« Tough Medicine For Medical Device Makers | Main | An Effective Compliance Program Redux »
Wednesday
Dec052007

Release 07-02, Where Are You?

We noticed a week ago that U.S. Department of Justice Opinion Procedure Release No.: 07-02 (September 11, 2007) is missing. It no longer appears on the DOJ's website that indexes all FCPA Releases (here). The text of the Release is still available from the old link here, but not through the index.

Release 07-02 is one of our favorites -- as discussed here and here. It deals with a problem-filled defense written into the U.S. Foreign Corrupt Practices Act that allows payment or reimbursement of expenses of foreign officials that are directly related to “the promotion, demonstration, or explanation of products or services." 15 U.S.C. §§ 78dd-1(c)(2)(A) and 78dd-2(c)(2)(A). Release 07-02 is (or was) the latest word on the subject from the DOJ.

We're trying to find out what happened to it, so stay tuned. Or better yet, if you have some news, please drop us a line. We'll be surprised if this isn't just a glitch in the DOJ's index. But until we know more, we'll include a caveat when we use Release 07-02 to give advice.

Note to Readers -- It's back! Release 07-02 again appears on the DOJ's index of FCPA Releases. Our thanks to the web wizards at the DOJ for fixing the problem. -- The Editors / posted on 06.12.07

Reader Comments

There are no comments for this journal entry. To create a new comment, use the form below.

PostPost a New Comment

Enter your information below to add a new comment.

My response is on my own website »
Author Email (optional):
Author URL (optional):
Post:
 
All HTML will be escaped. Hyperlinks will be created for URLs automatically.