Day 18 of One Month to Better Written Standards-Policies on Facilitation Payments
FCPA Compliance and Ethics Report-Episode 257-John Boscariol on facilitation payments
FCPA Compliance and Ethics Report-Episode 170-Yas Froemel 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
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
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
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
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