What do I do if a governmental official in another country requests a bribe, gift or other form of extra payment?

The U.S. Foreign Corrupt Practices Act makes it illegal to corruptly offer, promise or give anything of value to a foreign official or to a foreign political party or official of such party to obtain influence, induce an action or obtain an advantage.  The Act will also apply if you use an intermediary to effect such a payment.  The Act provides for criminal and civil penalties and will not permit Yale to reimburse any employee for penalties incurred, even inadvertently, under the Act.

It is important to note that many non-U.S. universities and hospitals are state-owned and run, thus making employees of these entities “foreign officials” for purposes of the Act.

For additional guidance in analyzing the Act or considering specific payments or gifts, please visit the Anti-Bribery Laws section of the International Toolkit or contact the Office of General Counsel.