Posted inRegulatory Enforcement

Facilitation Payments: Bribery or Business as Usual?

Companies still struggle mightily when it comes to crafting policies that address the use of facilitation payments. The payments—sometimes called “grease payments”—are small sums given to foreign officials to expedite normal business transactions, such as clearing goods through customs. Some distinguish them from bribes, which are typically meant to entice foreign officials to commit acts […]

Posted inRegulatory Enforcement

Justice Department Sheds Light on Charitable Giving and the FCPA

Charitable giving in foreign countries has always been a thorny issue for companies, since they fear that the giving could give way to allegations of violating the Foreign Corrupt Practices Act. This difficulty can be compounded when a company is designing and implementing a full corporate social responsibility strategy. The FCPA forbids companies from making […]

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