News & Analysis as of

Anti-Corruption Facilitation Payments

Thomas Fox - Compliance Evangelist

Arthurian Week: Part 3 – The Quest For the Holy Grail and Facilitation Payments

I thought about the quest for the Holy Grail in the context of the problem with facilitation payments. I see them to be as quixotic as the quest for the Holy Grail....more

Thomas Fox - Compliance Evangelist

The Problems with Facilitation Payments

The original version of the FCPA, enacted in 1977, contained an exception for payments made to non-U.S. officials who performed duties that were “essentially ministerial or clerical”. In 1988 Congress responded by amending...more

Blake, Cassels & Graydon LLP

No More Grease Payments – Canada Repeals Exception for Facilitation Payments

As part of Canada’s 2013 significant overhaul to its foreign corrupt practices regime, the Corruption of Foreign Public Officials Act (CFPOA), Canada indicated an intention to repeal the exception for facilitation payments....more

BCLP

We Can Ignore This French Sapin II Law, Right?

BCLP on

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

Akin Gump Strauss Hauer & Feld LLP

SEC Adopts New Rules Requiring Disclosure of Resource Extraction Payments

On June 27, 2016, the Securities and Exchange Commission (SEC) adopted new rules requiring certain producers of oil, natural gas and minerals to publicly disclose information regarding payments to the U.S. federal government,...more

Bennett Jones LLP

Tougher Canadian Foreign Corruption Law Raises the Stakes for Officers and Directors

Bennett Jones LLP on

Canada has significantly strengthened its Corruption of Foreign Public Officials Act (CFPOA) including by adding a new offence that will expand the grounds for criminal liability for corporations and their directors, officers...more

Morgan Lewis

Canadian Government Announces Proposed Amendments to Anticorruption Law

Morgan Lewis on

Amendments aim to improve enforcement of Canadian foreign corruption law by expanding jurisdiction, creating a books and records offense, eliminating the facilitation payments exception, redefining "business" and enforcement...more

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