Gifts Vs. Bribes Under The FCPA

Under the Foreign Corrupt Practices Act, bribes can result in hefty fines or prison. But the guidance from DOJ/SEC acknowledges that “a small gift or token of esteem or gratitude is often an appropriate way for business people to display respect for each other.” An article from LexisNexis provides some tips on how to tell the difference, how to formulate policies that make the difference as clear as possible, and how to establish internal controls that insure the policies are carried out.