News & Analysis as of

Facilitation Payments Compliance

Latham & Watkins LLP

Japanese Ministry of Economy, Trade and Industry Updates Guidance to Prevent Foreign Bribery

Latham & Watkins LLP on

Companies with business operations in Japan should review due diligence procedures and internal policy regarding small facilitation payments to ensure they are consistent with new guidance from METI. In May 2021, the...more

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

BCLP

Foreign Corrupt Practices Act Enforcement: 2017 Year-in-Review

BCLP on

Enforcement of the Foreign Corrupt Practices Act (FCPA) again remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2017, resulting in 11 companies paying over $1.92 billion to...more

Bennett Jones LLP

Facilitation Payments Declared Illegal Under Canadian International Corruption Law

Bennett Jones LLP on

The government of Canada announced on October 30 that the exception allowing for facilitation payments under the Corruption of Foreign Public Officials Act (CFPOA) will be eliminated effective October 31, 2017....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

Thomas Fox - Compliance Evangelist

Doing Business in Cuba Under the FCPA

I want to consider the impending opening of Cuba to US business, what you can do now and what you must wait for until the embargo is lifted; all from the perspective of compliance with the Foreign Corrupt Practices Act...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

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 170-Yas Froemel and Facilitation Payments

In this episode I visit with Yas Froemel, a PhD student in Germany who has developed and academic interest in facilitation payments. We discuss her work, the Anti-Corruption Forum which she founded and her upcoming conference...more

Dorsey & Whitney LLP

The Origins of the FCPA: Lessons For Effective Compliance and Enforcement - Part Four

Dorsey & Whitney LLP on

This is the fourth part of an occasional series. The first is available here, the second here and the third here. The entire paper will be published by Securities Regulation Law Journal early next year. The volunteer...more

Thomas Fox - Compliance Evangelist

Does Your Company Still Allow Facilitation Payments?

One of the more confusing areas of the US Foreign Corrupt Practices Act (FCPA) is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes....more

The Volkov Law Group

Ignoring The Obvious: Facilitation Payments

The Volkov Law Group on

Chief Compliance Officers have plenty of issues to focus on when it comes to anti-corruption compliance. If you rank the risks, facilitation payments are not at the top of the list, especially if you have sales staff and...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

Pillsbury Winthrop Shaw Pittman LLP

UK Bribery Act: Red Light, Green Light or Mixed-Signals?

The UK Government has announced a review of the Bribery Act 2010 and its intent to reduce the cost of compliance for small and medium-sized businesses. The main focus will apparently be on facilitation payments. These are...more

The Volkov Law Group

Facilitation Payments: An Intractable Problem?

The Volkov Law Group on

It sounds easy on paper. A company announces that it has banned all facilitation payments. It is a worthy goal. It sounds admirable. The FCPA permits facilitation payments. The UK Bribery Act prohibits facilitation...more

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