News & Analysis as of

Enforcement Facilitation Payments

BCLP

Foreign Corrupt Practices Act Enforcement: 2017 Year-in-Review

BCLP on

Enforcement of the Foreign Corrupt Practices Act (FCPA) again remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2017, resulting in 11 companies paying over $1.92 billion to...more

The Volkov Law Group

Sanctions Enforcement – Facilitation Violations

The Volkov Law Group on

As sanctions enforcement continues to mature, the permutations of risks become more complex. One area where companies have significant exposure is when they can be accused of “facilitation.” ...more

Thomas Fox - Compliance Evangelist

Does Your Company Still Allow Facilitation Payments?

One of the more confusing areas of the US Foreign Corrupt Practices Act (FCPA) is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes....more

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