Part of the joy of the winter holiday season is exchanging presents with family, friends and colleagues. However, even the most well-meaning gift givers can sometimes cause more harm than good, particularly if they end up tying a bow on a Foreign Corrupt Practices Act violation.
The FCPA can turn the most wonderful time of the year into the one of the riskiest for companies that aren’t thinking carefully about the sorts of gifts, travel and entertainment they provide, and whether these might fall within the act’s purview. Companies should consider providing some seasonal guidance to employees and evaluating their own risks and processes to ensure that they don’t fall victim.
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