If an African village chief demands a chicken for permission to conduct some local business transaction, is that considered a facilitating payment under the Foreign Corrupt Practices Act?
The question may sound like a bit of FCPA-related humor—and OK, it really is pretty funny—but it also is a genuine example of the compliance questions global companies are facing these days when trying to stamp out bribery. It was one of many FCPA questions compliance executives struggled to answer last week at the Compliance Week 2008 annual conference.
(And for the record: Yes, the chicken would be a facilitating payment under the FCPA, since the chief is a quasi-government official seeking something of value to take action to help the business.)
Anyone following enforcement trends knows that the Department of Justice and the Securities and Exchange Commission have significantly increased their enforcement efforts... To get the full story, subscribe now.
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