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Compliance Meal and Entertainment Expenditures

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Womble Bond Dickinson

Handle with Care: FCPA Travel & Hospitality Expenses

Womble Bond Dickinson on

Two recent Foreign Corrupt Practices Act (FCPA) actions – a Department of Justice (DOJ) Opinion letter and an SEC settlement – underscore key diligence questions that legal and compliance departments should address when...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

Data Analysis Week – Part III: Data Analysis to Prevent Employee Fraud

I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...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

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 Volkov Law Group

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

The Volkov Law Group on

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

Holland & Knight LLP

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

Holland & Knight LLP on

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 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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