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present enforcement policy with respect to the preceding provi- sions of this section to potential exporters and small businesses that “AIT TY are unable to obtain specialized counsel on issues pertaining to such : provisions. Such guidance shall be limited to responses to requests The Foreig " under paragraph (1) concerning conformity of specified prospective Co rrupt conduct with the Department of Justice’s present enforcement policy Practices Act regarding the preceding provisions of this section and general explana- tions of compliance responsibilities and of potential liabilities under the preceding provisions of this section. (v) actions of a similar nature. (f) Definitions (B) The term “routine governmental action” does not include any decision by a foreign official whether, or on what terms, to award For purposes of this section: new business to or to continue business with a particular party, or any action taken by a foreign ofhcial involved in the decision-making (1)(A) The term “foreign official” means any officer or employee of process to encourage a decision to award new business to or continue a foreign government or any department, agency, or instrumentality business with a particular party. thereof, or of a public international organization, or any person act- ing in an ofhcial capacity for or on behalf of any such government or (g) Alternative Jurisdiction department, agency, or instrumentality, or for or on behalf of any such public international organization. (1) It shall also be unlawful for any issuer organized under the laws of the United States, or a State, territory, possession, or commonwealth (B) For purposes of subparagraph (A), the term “public international of the United States or a political subdivision thereof and which has organization” means— a class of securities registered pursuant to section 78/ of this title or (i) an organization that is designated by Executive Order pursuant which is required to file reports under section 780(d

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