Is there any affirmative defense in the FCPA's anti-bribery provisions?
The FCPA's anti-bribery provisions contain two affirmative defenses. The first affirmative defense is that the payment was lawful under the written laws of the foreign official's country, and the second is that the payment was for reasonable expenditures directly related to the promotion of a payor's products or services, or the execution of a contract between the parties.
