Danger: Routine Facilitating Payments Under FCPA

Law360, New York (April 19, 2011, 12:15 PM EDT) -- From Lagos to Hanoi and from Rio to Tashkent, customs officials have their hands out. Perhaps such payments have always been viewed by your organization as grease payments, usually related to obtaining customs clearances.

These payments are typically only minor and generally well under $100. However, a systemic pattern of making such small payments likely violates the U.S. Foreign Corrupt Practices Act, as well as other international anti-corruption laws and regulations. Violations of these laws, particularly the FCPA, can result in staggering fines and even prison...
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