Menu8/1/14: Facilitation payments continue to bedevil compliance officers, and for good reason. Tom Fox frames a post about facilitation payments by recognizing that they represent one of the most confusing elements of the FCPA. But, he notes, “Facilitation payments are small bribes but make no mistake about it, they are bribes.” So, how...does a company reconcile something that is “allowed” under the FCPA but may violate other laws and contradict the company’s business ethics policies and culture? In this post from his FCPA Compliance and Ethics Blog, Fox shines some welcome light on the law, enforcement and requirements surrounding facilitation payments.
