Alexandra Wrage on Gifts and Facilitation Payments [Podcast]

Compliance Perspectives show

Summary: <a href=""></a><br> <a href=""></a><br> By Adam Turteltaub<br><br> In many parts of the world, the giving and receiving of gifts is a normal business practice.  The challenge is that gift giving can pose significant risk and constitute a violation of the US Foreign Corrupt Practices Act (FCPA) or UK Bribery Act.<br> There is also great risk in the paying of facilitation payments for routine services.  They may be permissible under the FCPA but not under the Bribery Act.<br> So, what to do?<br> <a href="">Alexandra Wrage</a>, the founder and President of TRACE International advises extreme caution, for one.  Both gift giving and paying facilitation payments are better avoided.<br> If gifts must be given, she recommends developing simple, clear-cut guidance and to make it available online 24/7 so that employees have the policy direction they need at the time that they need it.  Pre-approved gifts can help make things even simpler and safer.<br> When it comes to facilitation payments, simpler is better and the simplest rule of all – don’t pay them, period – is likely best.  If the company has been making payments, stopping abruptly may be problematic, she warns.  It can be better to give everyone involved advanced warning to enable a smoother transition.<br> Listen in to her podcast to learn more about these two risky areas for global operations.<br>