In an article published in the July issue of the Compliance Week magazine, entitled “The UK Bribery Act: How to Mitigate the Risks or Prosecution for Making Facilitation Payments", authors Jonathan Feig and Richard Thomas discuss how companies can mitigate their risks of prosecution for making facilitation payments under the Bribery Act. This is an area that many US companies may have exposure to as the Foreign Corrupt Practices Act (FCPA) has an exception for facilitation payments but there is no corresponding exception or exemption under the Bribery Act.