What Is A Foreign Government ‘Instrumentality’ After The Esquenazi Decision?

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Last year, when the Securities Exchange Commission (SEC) and U.S. Justice Department (DOJ) probed several U.S. investment banks’ hiring practices in China, it should have come as little surprise to the legal and compliance departments of most U.S. companies that conduct business abroad. With broad familiarity of the Foreign Corrupt Practices Act (FCPA), which bars U.S. companies from offering money or gifts to foreign officials in order to win business, the practice of banks hiring sons and daughters of prominent Chinese government officials certainly raised some obvious "red flags."

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