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 charitable contributions directed by foreign officials as a way to win or keep business. Late last year the Department of Justice shed some light on the topic when it issued its only opinion release of the year in which it addressed a scenario where it would not consider an act of charitable giving to raise potential FCPA violations.
