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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Posts Tagged: Facilitating Payments

Coordinated guidance from DC and London?

It was an odd event a few weeks ago when the U.K.’s Serious Fraud Office removed some Bribery Act guidance from its website without explanation.

The deleted guidance dealt with self reporting, corporate hospitality, and facilitating payments.… Continue Reading

Mini survey result: facilitating payments

The question was: Does your organization allow facilitating payments?

Nearly sixty-five percent said never.

Almost a quarter said sometimes, and less than one percent said always. Five percent didn’t know.

One respondent said he or she is ‘still trying to get management to make a decision’ about facilitiating payments.… Continue Reading

Petty corruption causes massive misery for the poor

People in Zimbabwe who can’t afford small bribes often lose out on birth certificates and passports.

An investigative report by the Standard said, “The forms of corruption reported [in the Registrar General’s Office] ranged from individuals selling queue positions, selling access to a registration officer, and selling even the right to be acknowledged and served within the RG’s Office.”… Continue Reading

Facilitating Payments And The Reporting Dilemma

Compliance insider Pete from DC first appeared on this blog nearly five years ago.

We’re happy to report that he still drops by.

In response to yesterday’s Small (Bribe) Talk From The Editors, Pete sent this comment:

*     *     *

Dear Editors:

Fascinating discussion, and I think Marc Alain Bohn’s point about transparent recording deserves a bit more attention, as it puts public companies (i.e.,… Continue Reading

Facilitating Payments (De)mystified (Conclusion)

In two prior posts we observed an awkward equivocation on the question of facilitation payments, both within the OECD generally and among the convention signatories. For a discussion of the OECD Convention’s strangely evasive verbiage, see here; for variations among individual signatories, see here.… Continue Reading

Facilitating Payments (De)mystified (Part I)

I’ve got a five-year-old daughter on a big synonym/antonym/homonym kick. If you don’t like talking about these things, you won’t like talking to her. But I love it, so let me give you a little quiz: in the FCPA context, are ‘ease’ and ‘facility’ antonyms or synonyms?… Continue Reading

Compliance Officers Troubled By Third-Party Risk

A new FCPA study from Kroll (a sponsor of the FCPA Blog) found that the majority of corporate compliance officers at U.S. multinationals believe they’re exposed to bribery risk and fall short on best practices when it comes to third party screening, facilitating payments, and political donations.… Continue Reading