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1As published by the American Bar Association in the December 2021 issue of The Health LawyerINTRODUCTIONFor life sciences and healthcare companies ac-customed to operating within the bounds of U.S. fraud and abuse laws, certain gaps be-tween domestic and international anti-cor-ruption laws can cause compliance challenges  is article focuses on two such gaps.First, unlike the Anti-Kickback Statute (AKS), the Foreign Corrupt Practices Act (FCPA) lacks safe harbors that expressly permit a range of routine interactions between pharmaceuti-cal, medical device, and healthcare companies, on the one hand, and individual healthcare professionals (HCPs) and institutions, on the other Attorneys from the FCPA Units of the U.S Department of Justice (DOJ) and U.S Securities and Exchange Commission (SEC) generally do not approach these issues from a U.S healthcare compliance perspective; they are often skeptical of certain arrangements with HCPs that are common in the United States and can be struc...