Regulatory Compliance Certification (RCC)

Which affirmative defense is explicitly available under the FCPA anti-bribery provisions?

The payment was below a materiality threshold of $5,000 The payment was a reasonable and bona fide business expenditure directly related to promoting products or services The company self-reported the violation within 30 days of discovery The foreign official voluntarily solicited the payment

Correct Answer:

The payment was a reasonable and bona fide business expenditure directly related to promoting products or services

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