FCPA: Travel Entertainment & Gifts
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The document discusses factors related to assessing whether travel, entertainment, and gifts provided to foreign officials could violate the Foreign Corrupt Practices Act. It outlines a 3-part test to determine permissibility: 1) the expenditure must be legal under the written laws of the foreign official's country; 2) the expenditure must be reasonable and for a legitimate business purpose; and 3) the expenditure must be directly related to promoting the company's products/services or executing a contract. It provides examples from case law where expenditures were deemed impermissible due to being lavish or not having a clear business purpose.
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![Foreign Corrupt Practices Act: Travel, Entertainment, and Gifts Philip Urofsky Direct: +1 (202) 508-8060 Cell: +1 (202) 415-7362 Email: [email_address] Danforth Newcomb Direct: +1 (212) 848-4184 Cell: +1 (917) 971-5774 Email: [email_address]](https://image.slidesharecdn.com/dcdocs01376478v1sspresentationontravelentertainmentgifts-124483740991-phpapp01/85/FCPA-Travel-Entertainment-Gifts-1-320.jpg)
![Anti-Bribery Elements ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]](data:image/gif;base64,R0lGODlhAQABAIAAAAAAAP///yH5BAEAAAAALAAAAAABAAEAAAIBRAA7)
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FCPA: Travel Entertainment & Gifts
- 1. Foreign Corrupt Practices Act: Travel, Entertainment, and Gifts Philip Urofsky Direct: +1 (202) 508-8060 Cell: +1 (202) 415-7362 Email: [email_address] Danforth Newcomb Direct: +1 (212) 848-4184 Cell: +1 (917) 971-5774 Email: [email_address]
- 12. Summary of DOJ Releases X X X X X X X No gifts / gifts with logo / samples X X X X X 08-03 X X X X Only routine business X 07-02 X X X X Potential future business X 07-01 X X X X Only routine business X 04-04 X X X X X X 04-03 X X X X X X 04-01 N/A N/A N/A Potential future business X 81-02 No / modest leisure No exp. for family Costs paid to provider / upon receipt / modest stipend “ Traveler” selected by employer No / limited business with employer Employer notified Release