Don’t Miss The FCPA Forest For The Gifts, Meals And Entertainment Trees

Contrary to what’s been written in some recent articles, companies should not fear a Foreign Corrupt Practices Act crackdown on gifts, meals and entertainment, according to compliance attorney Michael Volkov. Rather, he suggests, compliance officers must be vigilant, as always, with regard to access to money and ensuring that every expenditure is made with proper controls and assurances. “A single-minded focus on gifts, meals and entertainment expenses will leave a company exposed to significant risks in other areas where money can be improperly obtained to carry out bribery,” he writes.