31 Days to a More Effective Compliance Program - Policies and procedures on gifts and business entertainment

Thomas Fox
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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 regarding gifts and business entertainment. However, there have been some notable FCPA enforcement actions in this area.

Three key See more +

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 regarding gifts and business entertainment. However, there have been some notable FCPA enforcement actions in this area.

Three key takeaways:

1. Gifts and business entertainment continue to plague companies for compliance violations.

2. The key is not the amount but of having a policy and procedure and following it.

3. Always remember to record gifts and business entertainment expenses correctly. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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