No. 80-01

Date October 29, 1980

The Department of Justice has received a review request from an American law firm which seeks to do business in a foreign country. The law firm proposed to establish a fund for the American education and support, amounting to a total of approximately $10,000 per annum, for two individuals who are the adopted children of an honorary official of the government of the same foreign country. This official, who is elderly and a semi-invalid, has duties which are only ceremonial and do not involve substantive decision-making responsibilities. The natural parents of the two children are living and are employees of the foreign government. However, the natural parents are not in a position to make or to influence official decisions that would in any way benefit either the law firm or any corporations which may contribute to the education fund, in their dealings with the foreign government.

There has been no suggestion that any preferential treatment would be granted in return for the proposed conduct. Since its original contact with the foreign government, no business has been obtained or retained by the firm as a result of the proposed conduct, nor is any expected.

Based on all of the facts and circumstances as represented by the requester, the Department does not presently intend to take an enforcement action with respect to any of the prospective conduct described in the request.

The FCPA Review Letter and this Release have no application to any party which did not join in the request, and can be relied upon by the requesting parties only to the extent that the disclosure of facts and circumstances in the request is accurate and complete and continues to accurately and completely reflect such facts and circumstances.