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F.C.P.A. : Issuers :
(c) Affirmative defenses

It shall be an affirmative defense to actions under subsection (a) of this section that :

  1. The payment, gift, offer, or promise of anything of value that was made, was lawful under the written laws and regulations of the foreign official's, political party's, party official's, or candidate's country; or

  2. The payment, gift, offer, or promise of anything of value that was made, was a reasonable and bona fide expenditure, such as travel and lodging expenses, incurred by or on behalf of a foreign official, party, party official, or candidate and was directly related to--

    A) the promotion, demonstration, or explanation of products or services; or

    B) the execution or performance of a contract with a foreign government or agency thereof.

Exception Guidelines by Attorney General

 

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