b. You are trying to collect an overdue payment of R163,000 on a shipment of milk powder to the Dominican Republic. A senior government official asks for R20,000 as a collection service fee. Should you pay?
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yes
Explanation:
Examining the root causes of certain Foreign Corrupt Practices Act enforcement actions is not meant to rationalize or condone the conduct at issue, but just to better understand the circumstances given rise to the enforcement action in the first place.
For instance, like several other FCPA enforcement actions highlighted in this post, a root cause for a portion of the conduct alleged in the recent PDVSA related individual enforcement action is that Venezuela was unable to pay its bills and that alleged “foreign officials” offered to pay the outstanding bills (among a stack of many no doubt) in exchange for things of value.
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