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
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 government of Canada announced on October 30 that the exception allowing for facilitation payments under the Corruption of Foreign Public Officials Act (CFPOA) will be eliminated effective October 31, 2017....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
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
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 volunteer...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
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