Foreign Corrupt Practices Act

Something of Value

“Something of value” extends beyond cash and gifts.  Examples that could qualify as having value for purposes of the FCPA:

  • Per diems/daily allowances
  • Travel, meals, entertainment or gifts
  • Training/scholarships
  • Conference and event scholarships
  • Employment (e.g., paid internships for the child of an official)
  • Use of certain vendors (e.g., a vendor owned by a foreign official)
  • Medical care
  • Charitable donations

It may be possible to provide one of the above to a foreign official without violating the FCPA but it will require advance planning with the Office of the General Counsel.

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