News & Analysis as of

Facilitation Payments Books & Records

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

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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