Revisiting the Definition of 'Declinations'

The FCPA Blog
In this article, Marc Alain Bohn responds to a recent post by the FCPA Professor on use of the term "declination" for any instance of an FCPA review that does not end in an FCPA enforcement action. While the FCPA Professor presented a strong argument for a more narrow definition of the term, Bohn notes that with the current lack of transparency on the part of the agencies, there is no perfect definition for "declination." To avoid miscommunication, the real key is to be clear in how one is using the term.
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