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…

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