For Question 2 RE: Gift/Bribe. This could be considered a facilitation payment which is not prohibited under the FCPA.
The SEC Office of Investor Eduction says: "The FCPA does not apply to any "facilitating or expediting payment," the purpose of which is to expedite or secure the performance of a "routine governmental action." Routine governmental action encompasses those actions which ordinarily and commonly are performed by a foreign official in: (a) obtaining permits, licenses ...."
Notice how the payment to expedite (or boosting in the question) is not prohibited.
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Mark Batson CMA
Director/Manager
FUJIFILM Recording Media U.S.A., Inc.
North Billerica MA
United States
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Original Message:
Sent: 04-22-2020 12:43 PM
From: Sara Hussein
Subject: Please, I need an advice
Thank you for your help.
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Sara Hussein
Student
Cairo
Egypt
Original Message:
Sent: 04-22-2020 12:27 PM
From: Leonard Williams
Subject: Please, I need an advice
Hi Sara,
I passed part 2 in 2018. I used the Gleim CMA review which worked well but I am sure others would work well two. I got the most use out of the book, questions and the audio lectures. I didn't like the video lectures. If I had it to do over again I would just have gotten the book and access to the questions.
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Leonard Williams CMA
Accountant
Gillette WY
United States
Original Message:
Sent: 04-21-2020 03:10 PM
From: Sara Hussein
Subject: Please, I need an advice
Hi All,
I need your opinions and help, I want to start part 2 after i passed part 1 i am a senior student. I need to know should i purchase a complete review course (with lectures) for part 2 or just purchase the book+questions bank and study by myself ?
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Sara Hussein
Student
Cairo
Egypt
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