When Does a Grease Payment Become a Bribe Under the FCPA?

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One of the more vexing questions under the Foreign Corrupt Practices Act (FCPA) is when does a facilitation payment become a bribe? It is not uncommon to hear stories about demand for payments

But the question still remains for the FCPA Practitioner who must provide concrete guidance to the field personnel, when does a facilitation payment become something illegal under the FCPA?

The FCPA landscape is littered with companies which sustained FCPA violations due to payments which did not fall into the facilitation payment exception.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox, Compliance Evangelist | Attorney Advertising

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