FCPA Compliance and Ethics Report-Episode 94-Internal Controls for Gifts, Travel and Entertainment in a FCPA Compliance Program, Part II
FCPA Compliance and Ethics Report-Episode 53-Gifts, Travel and Entertainment Under the FCPA
Gift-giving is common in many workplaces, especially during the holiday season. While giving your coworker or customer a present can help to build business relationships, not all forms of gift-giving happen with such...more
If one were to reflect upon the providing of gifts and business entertainment to foreign governmental officials, one might reasonably conclude that after 40 years of the FCPA, companies might follow its prescriptions...more
We continue our Christmas entertainment-themed week by going in a different direction and focusing solely on music today. Greg Lake is best remembered as the guitarist for the prog rock trio, Emerson, Lake and Palmer. While...more
Welcome to Compliance Notes from Nossaman’s Government Relations & Regulation Group – a periodic digest of the headlines, statutory and regulatory changes and court cases involving campaign finance, lobbying compliance,...more
Companies should identify and, where appropriate, manage risk associated with gifts and entertainment by incorporating a clear policy into their overall corporate compliance strategy. On September 11, 2020, the French...more
Based upon the language of the Foreign Corrupt Practices Act (FCPA), 2012 FCPA Guidance, FCPA enforcement actions and relevant Opinion Releases, and allowing for inflation over the past 40 years, it would appear reasonable...more
Ed. Note-Jim McGrath was a great friend and a trusted colleague who passed away in 2014. As a tribute to McGrath and each year for Christmas, I submit for your enjoyment, the below post which originally appeared on McGrath’s...more
In considering the effectiveness of controls, you must always keep in mind the most frequently used method for defeating an internal control, which is driven by a dollar amount criteria, is splitting the item into multiple...more
This year, India celebrates Diwali on October 19, 2017. “The Festival of Lights,” as Diwali (or Deepavli) is commonly called, is celebrated across India with great aplomb, joy and, of course, delicious sweets. Diwali...more
Rock and roll heaven got another power player this week as Greg Lake died on December 7th. He was one-third of the greatest prog rock trio Emerson, Lake & Palmer (aka ELP). With apologies to Patrick Hays and all you...more
The Alabama Ethics Commission (the “Commission”) held a regularly scheduled meeting on October 5, 2016. At the meeting, the Commission formally extended the comment period for two significant advisory opinions affecting...more
FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more
Life can be very humbling. The SEC has definitely humbled me. For years now, I have been claiming that companies spend too much time worrying about gifts, meals and entertainment expenses under the FCPA, rather than...more
In this episode of the FCPA Compliance and Ethics Report I continue my visit with Henry Mixon on internal controls for gifts, travel and entertainment in a best practices FCPA compliance program. ...more
It was the week before Chinese New Year. The financial year had ended weeks earlier and unpaid invoices had made a dent in the annual performance of the small family business. For months, the foreign husband, a co-owner of...more
In this episode I review gifts. travel and entertainment under the FCPA. ...more
Now that we have reviewed all of the public record pronouncements from the Department of Justice (DOJ) and Securities and Exchange Commission (SEC), this post will try and suggest what you might need in your Foreign Corrupt...more
Last week the Department of Justice formally charged ex-Virginia Governor Bob McDonnell and his wife with illegally soliciting and accepting lavish gifts and entertainment as well as loans from the (now former) CEO of Star...more
Today’s post comes from Venice where I am spending a week. It is one of the most unique and beautiful cities on earth. It was a great maritime power for over 1000 years. At the height of its power, it was the richest city on...more
It is time for everyone to take a deep breath. The DOJ/SEC Guidance could not have been clearer. The message to companies – stop devoting so much time to building, tinkering with, and monitoring their policies governing...more