31 Days to a More Effective Compliance Program - Policies on Facilitation Payments

Thomas Fox
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From the information provided by the DOJ in Opinion Releases and in enforcement actions, there are several different insights which may be drawn on regarding what should go into your policy on facilitation payments. Do not forget that facilitation payments must be accurately shown on the books and records of your company. In all cases the employee who requested permission to make the facilitation payment must be responsible for obtaining all required approvals and forwarding a copy of the approvals and any other relevant supporting See more +
From the information provided by the DOJ in Opinion Releases and in enforcement actions, there are several different insights which may be drawn on regarding what should go into your policy on facilitation payments. Do not forget that facilitation payments must be accurately shown on the books and records of your company. In all cases the employee who requested permission to make the facilitation payment must be responsible for obtaining all required approvals and forwarding a copy of the approvals and any other relevant supporting documentation as required, so that the it is recorded as a facilitation expense in the books and records and maintained in a central file. Facilitation payments should not be recorded as consulting fees, entertainment expenses, or other types of expenses that may misrepresent the true nature of the payments. 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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