Anti-Corruption Certification

To get certified

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Term Definition

Something that serves as an intermediary or agent through which one or more functions of a larger controlling entity are carried out: a part or branch especially of a governing body. In the US, the DOJ and SEC have construed “instrumentalities” to encompass State-Owned Enterprises (“SOE”). In the eyes of the DOJ and SEC, officers and employees of SOEs are all “foreign officials” under the FCPA