As anti-bribery enforcement goes increasingly global, some companies are opting to ban facilitation payments entirely to avoid the tricky compliance issues they pose.
A survey conducted by TRACE International shows some companies are prohibiting facilitation payments—colloquially known also known as “grease payments”—which are given to induce foreign officials to perform routine functions they’re already obligated to perform, such as issuing licenses or permits and installing telephone lines. In theory, such payments simply nudge foreign officials to do their jobs more promptly.
In practice, however, the line between a permissible facilitation payment and an illegal bribe can be very blurry. And to complicate ...