When it comes to global bribery laws and FCPA compliance, travel and entertainment expenses and the reimbursement process are enormously meaningful in many ways. So how can you make sure that your risk, compliance, and audit departments are properly tracking these processes and effectively mitigating risk?… Continue Reading
Posts Tagged: travel and entertainment expenses
Corporate executives, especially CFOs, are aware of the importance of travel and entertainment expenses, particularly within industries that require at least some level of spending in order to generate business leads.… Continue Reading
Yesterday’s post addressed abuse of travel agencies. Today’s post addresses “training” trips, factory “inspections,” “study trips,” and other euphemisms for disguised leisure travel.
Companies in China often pay for training trips for their customers. … Continue Reading
In any country, paying for travel for government officials, customers at state-owned enterprises, or customers at purely private enterprises can present corruption risks. Many worthy publications have addressed travel risks generally and how to minimize those risks, including establishing a true business purpose for the trip, ensuring transparency with the recipient’s organization, pre-approving a detailed itinerary to ensure that sightseeing/leisure does not predominate, paying expenses directly to vendors where possible, avoiding unnecessary stopovers or family members or friends accompanying, etc.… Continue Reading
Minnesota-based MTS Systems Corporation said last week that after an investigation of gift-giving, travel, and accommodation practices in its Asia operations, it ‘[removed] certain persons formerly employed in its Korea office.’… Continue Reading
Last month, the Criminal Division of the U.S. Department of Justice and the Securities and Exchange Commission published their long-awaited Resource Guide to the U.S. Foreign Corrupt Practices Act.
At 120 pages, this document is intended to assist companies to navigate seemingly arbitrary rules around what does and does not constitute legal behavior when dealing with overseas business practices.… Continue Reading
Last week, the DOJ and SEC issued their long-anticipated Resource Guide regarding the agencies’ FCPA enforcement. Over a year in the drafting, the 120-page Guide addresses, among other things, (1) the definition of a foreign official, (2) gifts and entertainment, and (3) the “hallmarks” of an effective corporate compliance program.… Continue Reading
Here’s what Robert Khuzami said Wednesday at a news briefing about the FCPA guidance released by the DOJ and SEC. Khuzami is head of the SEC’s enforcement division.
* * *
The most effective law enforcement programs are those that combine vigorous prosecution of those who break the law with an equally vigorous effort to enable those who seek to abide by the law.… Continue Reading