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Is a cup of coffee a reportable FCPA violation?

Tom Fox | October 20, 2016

What’s next, a cup of coffee bought for a custom’s official while you are waiting for the inspection? That is the question which came to the mind of The Man From FCPA when he read about the self-disclosure made to the Justice Department by Lennox International over a $475 facilitation payment made by the company in Russia. In its October, 10-Q filing the company stated, “In October 2016, the company self-reported to the Securities and Exchange Commission (SEC) and the Department of Justice (DoJ) an alleged payment in the amount of 30,000 rubles (approximately U.S. $475) to a Russian customs broker or official. The company, under the oversight of its Audit Committee, has initiated an investigation into this matter with the assistance of external legal counsel and external forensic accountants.”

The howling over this disclosure was far and wide. The FCPA Professor asked if this was “the most absurd voluntary disclosure ever?” The FCPA Blog said...

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