FCPA Compliance and Ethics Report-Episode 170-Yas Froemel and Facilitation Payments
In this episode I visit with Yas Froemel, a PhD student in Germany who has developed and academic interest in facilitation payments. We discuss her work, the Anti-Corruption Forum which she founded and her upcoming conference...more
Recent OFAC and DOJ actions have focused on certain entities – overseas financial institutions – and particular conduct – US dollar clearing and associated “stripping.” The DOJ’s recent $232 million settlement and negotiated...more
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
Two famous New Yorkers died this week. Both spoke to not only to the glamour of the Big Apple, but the city’s once undisputed crown as the cultural mecca of the US. They were Allie Sherman and Bess Myerson....more
TOP 10 TIPS FOR COUNTERING SMALL BRIBES -
The issue of so-called facilitation payment’ and other small bribes is a thorn in the side of many international businesses. Not only is it difficult to do business in many...more
This is the fourth part of an occasional series. The first is available here, the second here and the third here. The entire paper will be published by Securities Regulation Law Journal early next year.
The issue of so-called facilitation payments and other small bribes is a thorn in the side of many international businesses. Not only is it difficult to do business in many parts of the world without making such payments, but...more
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
On July 23, Thomas Baxter, General Counsel for the New York Federal Reserve Bank, in public remarks at a risk management conference, questioned the FCPA’s “exception for ‘facilitating or expediting payments’ made in...more
Chief Compliance Officers have plenty of issues to focus on when it comes to anti-corruption compliance. If you rank the risks, facilitation payments are not at the top of the list, especially if you have sales staff and...more
From our deck chairs we thought we’d share this with you. An open letter from David Green, Director of the SFO, in connection with facilitation payments.
Originally Published on thebriberyact.com - August 22, 2013....more
Canada has significantly strengthened its Corruption of Foreign Public Officials Act (CFPOA) including by adding a new offence that will expand the grounds for criminal liability for corporations and their directors, officers...more
The UK Government has announced a review of the Bribery Act 2010 and its intent to reduce the cost of compliance for small and medium-sized businesses. The main focus will apparently be on facilitation payments. These are...more
News reaches us of a private small round table session put together by Transparency International and attended by some from the US FCPA white collar community (we understand Mark Mendelsohn attended) and our very own David...more
It sounds easy on paper. A company announces that it has banned all facilitation payments. It is a worthy goal. It sounds admirable.
The FCPA permits facilitation payments. The UK Bribery Act prohibits facilitation...more
Amendments aim to improve enforcement of Canadian foreign corruption law by expanding jurisdiction, creating a books and records offense, eliminating the facilitation payments exception, redefining "business" and enforcement...more
In the wake of recent anti-corruption cases brought against two Canadian companies, the Government of Canada has signaled its continuing commitment to fight foreign corruption by proposing significant amendments to the...more
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