No. 82-01
Date: January 27, 1982
Foreign Corrupt Practices Act
Review Procedure Release
The Department of Justice has received a review request from the Department of Agriculture of the State of Missouri pursuant to the Foreign Corrupt Practices Act Review Procedure.
In an effort to promote sales of Missouri agricultural products in Mexico, the Department of Agriculture of the State of Missouri intends to host representatives of Mexican government agencies and instrumentalities, such as a state-controlled bank, and individuals representing Mexican private sector agricultural businesses in a series of meetings in conjunction with representatives of agricultural businesses in Missouri, as well as business organizations such as the Missouri Chamber of Commerce. It is expected that the Missouri Agricultural Department will pay the reasonable and necessary expenses of the Mexican delegation, which is expected to consist of approximately 10 persons. These expenses will include those for lodging, meals, entertainment and travel within the State of Missouri. The Department expects to pay these expenses using its own funds and through contributions made to the Department by private business firms in the state. Some direct expenditures may also be made by such firms in connection with the hosting of meals, receptions or demonstrations of the products of one or more firms. It is also contemplated by the Missouri Department of Agriculture that various business representatives may furnish members of the Mexican delegation with samples of their products e.g., a selection of Missouri cheeses, and/or other items of minimal value.
In the event that any member of the Mexican delegation should inadvertently pay directly for lodging, meals or local travel, the Agriculture Department proposes to reimburse that member for his or her expenditure, provided an adequate receipt is furnished.
Based on all the facts and circumstances as represented by the requestor, the Department does not presently intend to take an enforcement action with respect to the hosting of the Mexican delegation as proposed by the requesting party.
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 party 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. |
