It was a record year for U.S. federal prosecution of corruption and fraud. The Justice Department Criminal Division in 2019 charged more individuals, and secured more guilty pleas, for violations of the Foreign Corrupt Practices Act than in any year since it was enacted four decades ago. This topped the previous two years, which were also records. What does this have to do with corporate travel? A lot, actually.

According to updated guidance published by DOJ in April . . .

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