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 they might otherwise not do, such as awarding a contract.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...