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
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
Wrong. The law Sapin II (Law 2016-1691 of 27 December 2016) has been in force for several months, but the consultation draft of the guidelines is not expected to be issued by the Agence Française Anti-corruption (AFA) (French...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
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
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