Meal and Entertainment Expenditures

News & Analysis as of

Gifts, Travel And Entertainment Under The FCPA – Part I

One of the first thing that many companies will try to put in place is a gifts, entertainment and travel policy when looking at an overall compliance program. I find the reality to be that not only is this one of the more...more

The So-Called Re-Emergence Of Gifts, Meals And Entertainment As A Compliance Problem

Forgive me for taking the FCPA Paparazzi to task but when they deserve it, they deserve it. A quick diversion — I often am asked by fellow bar members and commenters if I am referring to them as being a member of the...more

Don’t Be a Grinch: A Holiday Gift Guide to Your Gifts and Entertainment Policy

Every year around the holidays the U.S. Office of Government Ethics republishes their holiday poem on gifts and entertainment as a reminder to all of us of what is acceptable and what is not. So as the year draws to a close,...more

Meals and Golf Outings Paid For By Subcontractors May Trigger Double Damages Under Anti-Kickback Act

Federal prime contractors and subcontractors should consider reviewing and updating compliance procedures and employee training relating to entertainment and other business development gratuities in the wake of the Fifth...more

The Truth Behind Gifts, Meals And Entertainment Enforcement

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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