Day 18 of One Month to Better Written Standards-Policies on Facilitation Payments
FCPA Compliance and Ethics Report-Episode 257-John Boscariol on facilitation payments
FCPA Compliance and Ethics Report-Episode 170-Yas Froemel and Facilitation Payments
Companies with business operations in Japan should review due diligence procedures and internal policy regarding small facilitation payments to ensure they are consistent with new guidance from METI. In May 2021, the...more
One of the more confusing areas of the FCPA is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes. For that reason, many companies feel they are inconsistent...more
I thought about the quest for the Holy Grail in the context of the problem with facilitation payments. I see them to be as quixotic as the quest for the Holy Grail....more
The original version of the FCPA, enacted in 1977, contained an exception for payments made to non-U.S. officials who performed duties that were “essentially ministerial or clerical”. In 1988 Congress responded by amending...more
As part of Canada’s 2013 significant overhaul to its foreign corrupt practices regime, the Corruption of Foreign Public Officials Act (CFPOA), Canada indicated an intention to repeal the exception for facilitation payments....more
I want to consider the impending opening of Cuba to US business, what you can do now and what you must wait for until the embargo is lifted; all from the perspective of compliance with the Foreign Corrupt Practices Act...more
Today, I conclude my weeklong exploration of doing business in Cuba from the perspective of the Foreign Corrupt Practices Act (FCPA) with some final observations. One of the key themes throughout this week’s blog posts has...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
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
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
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
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