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Foreign Corrupt Practices Act (FCPA) Corporate Gifts

NAVEX

Avoiding Bribery and Corruption: A Gift Giving Guide

NAVEX on

Gift-giving is common in many workplaces, especially during the holiday season. While giving your coworker or customer a present can help to build business relationships, not all forms of gift-giving happen with such...more

Thomas Fox - Compliance Evangelist

A Primer on Gifts and Business Entertainment

If one were to reflect upon the providing of gifts and business entertainment to foreign governmental officials, one might reasonably conclude that after 40 years of the FCPA, companies might follow its prescriptions...more

Thomas Fox - Compliance Evangelist

I Believe in Father Christmas and Internal Controls for Gifts in the Holiday Season

We continue our Christmas entertainment-themed week by going in a different direction and focusing solely on music today. Greg Lake is best remembered as the guitarist for the prog rock trio, Emerson, Lake and Palmer. While...more

Wilson Sonsini Goodrich & Rosati

Telefônica Brasil Case Reinforces Risks of Gifts and Hospitality Involving Foreign Officials

On May 9, 2019, Telefônica Brasil agreed to pay a US$4.13 million civil fine to settle U.S. Securities and Exchange Commission charges for violations of the internal accounting controls and recordkeeping provisions of the...more

Thomas Fox - Compliance Evangelist

Scrooge and Gift Giving Over the Holidays

Based upon the language of the Foreign Corrupt Practices Act (FCPA), 2012 FCPA Guidance, FCPA enforcement actions and relevant Opinion Releases, and allowing for inflation over the past 40 years, it would appear reasonable...more

Thomas Fox - Compliance Evangelist

A Merry (compliance ) Christmas

Ed. Note-Jim McGrath was a great friend and a trusted colleague who passed away in 2014. As a tribute to McGrath and each year for Christmas, I submit for your enjoyment, the below post which originally appeared on McGrath’s...more

Thomas Fox - Compliance Evangelist

I Believe in Father Christmas and Internal Controls for Gifts in the Holiday Season (UPDATED)

In considering the effectiveness of controls, you must always keep in mind the most frequently used method for defeating an internal control, which is driven by a dollar amount criteria, is splitting the item into multiple...more

K2 Integrity

When the Well-Intentioned Holiday Gift Crosses the Line

K2 Integrity on

Sending the wrong gift to the wrong person could leave a company facing bribery charges. During the holiday season, we naturally want to acknowledge and thank our clients and vendors. Today, however, with stricter...more

Foley & Lardner LLP

Diwali: An Opportune Time for an Anti-Corruption Compliance Reminder

Foley & Lardner LLP on

This year, India celebrates Diwali on October 19, 2017. “The Festival of Lights,” as Diwali (or Deepavli) is commonly called, is celebrated across India with great aplomb, joy and, of course, delicious sweets. Diwali...more

Thomas Fox - Compliance Evangelist

I Believe in Father Christmas and Internal Controls for Gifts in the Holiday Season

Rock and roll heaven got another power player this week as Greg Lake died on December 7th. He was one-third of the greatest prog rock trio Emerson, Lake & Palmer (aka ELP). With apologies to Patrick Hays and all you...more

Thomas Fox - Compliance Evangelist

Booking a Meeting? In Venezuela It May Cost You a Rolex

First it was Petrobras but it certainly did not take long for the second shoe to drop for the other corrupt national energy company in Latin America, the Venezuelan national oil company Petróleos de Venezuela, also known as...more

Dechert LLP

FLIR FCPA Action Highlights: Continued Focus on Penalizing Improper Expenditures for Government Officials

Dechert LLP on

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more

The Volkov Law Group

Gifts, Meals and Then . . . FCPA Enforcement

The Volkov Law Group on

Life can be very humbling. The SEC has definitely humbled me. For years now, I have been claiming that companies spend too much time worrying about gifts, meals and entertainment expenses under the FCPA, rather than...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 94-Internal Controls for Gifts, Travel and Entertainment in a FCPA Compliance Program,...

In this episode of the FCPA Compliance and Ethics Report I continue my visit with Henry Mixon on internal controls for gifts, travel and entertainment in a best practices FCPA compliance program. ...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 53-Gifts, Travel and Entertainment Under the FCPA

In this episode I review gifts. travel and entertainment under the FCPA. ...more

Thomas Fox - Compliance Evangelist

Gifts, Travel And Entertainment Under The FCPA – Part III

Now that we have reviewed all of the public record pronouncements from the Department of Justice (DOJ) and Securities and Exchange Commission (SEC), this post will try and suggest what you might need in your Foreign Corrupt...more

Thomas Fox - Compliance Evangelist

Venice, The US Navy And Red Flags

Today’s post comes from Venice where I am spending a week. It is one of the most unique and beautiful cities on earth. It was a great maritime power for over 1000 years. At the height of its power, it was the richest city on...more

Parker Poe Adams & Bernstein LLP

A Bribe is a Bribe

Last week the SEC reported that Diebold, Inc. agreed to pay more than $48 million in fines and prejudgment interest to settle SEC civil charges and DOJ criminal charges that it had violated the Foreign Corrupt Practices Act....more

Thomas Fox - Compliance Evangelist

Not Draconian – Gift, Travel And Entertainment Under The FCPA

The Greek ruler Draco has received some very bad PR advice over the centuries. ...more

The Volkov Law Group

The Truth Behind Gifts, Meals And Entertainment Enforcement

The Volkov Law Group on

It is time for everyone to take a deep breath. The DOJ/SEC Guidance could not have been clearer. The message to companies – stop devoting so much time to building, tinkering with, and monitoring their policies governing...more

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