Honing a compliant gifts policy: the trends we are seeing today
By Laura L Flippin
As A Resource Guide to US FCPA acknowledges, the Foreign Corrupt Practices Act (FCPA) does not have a minimum threshold amount for corrupt gifts or payments — which can include providing travel, meals or entertainment. The guide further advises that gifts of nominal value are unlikely to result in enforcement action when they are ‘given openly and transparently, properly recorded in the giver’s books and records provided only to reflect esteem or gratitude, and permitted under local law’.
The guidelines companies develop to reflect these principles can vary widely, to address the different industries, cultures and environments in which they operate. While this variety can be frustrating to those seeking definitive guidance, a programme and guidelines developed to address a company’s specific risk profile in specific markets is critical, providing useful direction in day-to-day relationships and operations.
Some of the trends seen recently at different companies are included in this briefing…
If you are registered and logged in to the site, click on the link below to read the rest of the DLA Piper briefing. If not, please register or sign in with your details below.
News from DLA Piper
News from The Lawyer
Briefings from DLA Piper
The European Commission has announced its plans to both reshape the simplified merger notification process within the framework of the EUMR.
Five federal financial regulatory agencies have released final rules implementing Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
Analysis from The Lawyer
The Lawyer’s latest Top 50 litigation firms list shows that business for dispute specialists is roaring along while new in-depth detail reveals the winning strategies
Our list of the summer’s big deals shows how London law firms kept busy with work from Asia as well as more familiar sources