the clock is ticking now whether we're charged or not. FCPA is 5 years from the date that the alleged crime was committed and it can be tolled for an additional 2 years if the Government requests to gather evidence overseas. However, the government has to request those additional 2 years before the original 5 year statute of limitations has expired, so we might already be in the clear regarding the May 21, 2001 agreement if the government did not seek to have the statute of limitations tolled before May 21, 2006.
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