Skip to content

Editors

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

Con-way Settles FCPA Enforcement Action

Internal controls and books and records violations; impermissible “facilitating payments” to customs officials and bribes to airline employees

California-based Con-way, Inc., a global freight forwarder, has paid a $300,000 penalty and accepted a cease and desist order to settle a Foreign Corrupt Practices Act enforcement action with the Securities and Exchange Commission.… Continue Reading

Heading For The Hammock

It’s the weekend again. Good thing. We need (and deserve) some rest. What serious mind, after all, wouldn’t be exhausted pondering how Tampa Bay can be one and a half games clear of the Red Sox?… Continue Reading

Sweating The Small Stuff

Public corruption isn’t a victimless crime, and whatever helps dispel the false notion that it is, is welcome in this space. Which brings us to . . . the United Nations.… Continue Reading

A Hundred Tiny Bribes

More than a month ago — practically forever in the time-warped blogosphere — we mentioned that a reader had shared with us a soon-to-be published paper about facilitating payments. Well, the paper is now available.… Continue Reading

Great Words From The Hill, Circa 1977

Aside from the villa on Lake Como and the Aston Martin in the garage, the greatest perk that comes from tending this garden is hearing from so many talented experts in the field of the Foreign Corrupt Practices Act.… Continue Reading

One Law,Two Parts

The question comes from Pune, India: Can a payment that is not a bribe – such as a facilitating payment – be the basis for a criminal violation of the U.S.… Continue Reading

Tidewater’s Compliance Review Goes Global

The Importance of Being Cooperative; Are Facilitating Payments Causing More Problems?

Tidewater Inc. is now investigating its compliance with the U.S. Foreign Corrupt Practices Act worldwide, the company said in an October 4, 2007 press release.… Continue Reading

FCPA Defenses That Don’t Work

The text of the Foreign Corrupt Practices Act sets out three types of payments to foreign officials that are lawful — facilitating payments, promotional expenses and payments permitted under the written laws of the host country.… Continue Reading

Panalpina Suspends Services For Oil and Gas-Related Customers in Nigeria

Panalpina’s cooperation with the U.S. Department of Justice appears to be in full swing. For starters, it is exiting the Nigeria logistics and freight forwarding market for all oil and gas services customers, at least a dozen of which have been contacted by the DOJ about Panalpina’s customs clearance practices in Nigeria and other countries.… Continue Reading

Another Look At Facilitating Payments

As the lone exception written into the U.S. Foreign Corrupt Practices Act, facilitating payments have a reputation for being safe and practical. In truth, grease payments are often dangerous and potentially damaging.… Continue Reading

Panalpina’s Practices Fall Under the FCPA Spotlight

February 6, 2007 — The DOJ reports Vetco’s admission that payments to Nigerian Customs Officials violated the FCPA. The DOJ says, “These corrupt payments were paid through a major international freight forwarding and customs clearance company to employees of the Nigerian Customs Service, and coordinated largely through Vetco Gray Controls Inc.’sContinue Reading