A Primer on Facilitation Payments
By EsqSocial Corporation 26/04/21
One of the more confusing areas of the FCPA is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes. For that reason, many companies feel they are inconsistent with a company culture of doing business ethically and in compliance with laws prohibiting corruption and bribery. Further, the 2020 FCPA Resource Guide, 2nd edition specifies, “while the payment may qualify as an exception to the FCPA’s anti-bribery provisions, it may...
By: Thomas Fox