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Google Keyword Rankings for : facilitation payment cases
1
Facilitation payments - Case studies
https://briberyprevention.com/case-studies/facilitation-payments/
This is a case study for business owners on how to identify and respond to a request for a facilitation payment.
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https://briberyprevention.com/case-studies/facilitation-payments/
This is a case study for business owners on how to identify and respond to a request for a facilitation payment.
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2
A Primer on Facilitation Payments | Thomas Fox - JD Supra
https://www.jdsupra.com/legalnews/a-primer-on-facilitation-payments-5758744/
Facilitation payments are small bribes but make no mistake about it, they are bribes. For that reason, many companies feel they are inconsistent ...
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https://www.jdsupra.com/legalnews/a-primer-on-facilitation-payments-5758744/
Facilitation payments are small bribes but make no mistake about it, they are bribes. For that reason, many companies feel they are inconsistent ...
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3
8. Facilitation Payments - Anti-Bribery Guidance
https://www.antibriberyguidance.org/guidance/8-facilitation-payments/guidance
The term facilitation payment originates from the FCPA and usually covers payments made to officials to obtain or speed up routine services which the officials ...
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https://www.antibriberyguidance.org/guidance/8-facilitation-payments/guidance
The term facilitation payment originates from the FCPA and usually covers payments made to officials to obtain or speed up routine services which the officials ...
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4
Facilitation payments under the FCPA - Compliance Week
https://www.complianceweek.com/facilitation-payments-under-the-fcpa/8741.article
This case dealt with whether payment of bribes to obtain a favorable tax ruling was prohibited under the FCPA. In its opinion, the Fifth Circuit ...
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https://www.complianceweek.com/facilitation-payments-under-the-fcpa/8741.article
This case dealt with whether payment of bribes to obtain a favorable tax ruling was prohibited under the FCPA. In its opinion, the Fifth Circuit ...
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5
The FCPA & Facilitating Payments
https://whistleblowerjustice.net/the-fcpa-facilitating-payments/
Facilitating payments are an exemption to the FCPA, NOT an affirmative defense. This means that the accused company can claim an alleged bribe was a ...
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https://whistleblowerjustice.net/the-fcpa-facilitating-payments/
Facilitating payments are an exemption to the FCPA, NOT an affirmative defense. This means that the accused company can claim an alleged bribe was a ...
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6
SEC Enforcement Actions: FCPA Cases
https://www.sec.gov/enforce/sec-enforcement-actions-fcpa-cases
- The firm agreed to pay more than more than $1 billion to settle SEC charges that it violated the anti-bribery, books and records, and internal ...
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https://www.sec.gov/enforce/sec-enforcement-actions-fcpa-cases
- The firm agreed to pay more than more than $1 billion to settle SEC charges that it violated the anti-bribery, books and records, and internal ...
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7
Corruption and Companies: The Case of Facilitating Payments
https://www.researchgate.net/publication/4803179_Corruption_and_Companies_The_Case_of_Facilitating_Payments
Facilitating payments are a very widespread form of corruption. They consist of small payments or gifts made to a person -a public official ...
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https://www.researchgate.net/publication/4803179_Corruption_and_Companies_The_Case_of_Facilitating_Payments
Facilitating payments are a very widespread form of corruption. They consist of small payments or gifts made to a person -a public official ...
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8
Appendix H - Department of Justice
https://www.justice.gov/sites/default/files/criminal-fraud/legacy/2012/11/14/response3-appx-h.pdf
Survey #2 on Treatment of Small Facilitation Payments by Members ... Recent cases illustrate that the Department of Justice has.
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https://www.justice.gov/sites/default/files/criminal-fraud/legacy/2012/11/14/response3-appx-h.pdf
Survey #2 on Treatment of Small Facilitation Payments by Members ... Recent cases illustrate that the Department of Justice has.
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9
Facilitation payments - to pay or not to pay: a difficult question?
https://www.subjecttoinquiry.com/2011/05/facilitation-payments-to-pay-or-not-to-pay-a-difficult-question/
Facilitation payments, which are payments to induce officials to perform routine functions they are otherwise obligated to perform, are bribes.
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https://www.subjecttoinquiry.com/2011/05/facilitation-payments-to-pay-or-not-to-pay-a-difficult-question/
Facilitation payments, which are payments to induce officials to perform routine functions they are otherwise obligated to perform, are bribes.
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10
To Pay or not to Pay - Facilitation payments and corruption
https://www.unodc.org/documents/treaties/UNCAC/E-Learning/English/facilitation_payments_corruption/index.htm
What does the UN Convention against Corruption say about this type of payment? It's OK to make them, provided that this is a common practice in the country ...
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https://www.unodc.org/documents/treaties/UNCAC/E-Learning/English/facilitation_payments_corruption/index.htm
What does the UN Convention against Corruption say about this type of payment? It's OK to make them, provided that this is a common practice in the country ...
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11
At Large: It's a tempting time to (mis)use the 'facilitating ...
https://fcpablog.com/2020/09/30/at-large-its-a-tempting-time-to-misuse-the-facilitating-payments-exception/
A foreign official's approval of false paperwork is never “routine governmental action,” so the facilitating payments exception couldn't apply.
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https://fcpablog.com/2020/09/30/at-large-its-a-tempting-time-to-misuse-the-facilitating-payments-exception/
A foreign official's approval of false paperwork is never “routine governmental action,” so the facilitating payments exception couldn't apply.
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12
Facilitation payments – GIACC
https://giaccentre.org/facilitation-payments/
In some cases, the facilitation payment may be forcibly extracted from personnel by real or perceived threats to safety or liberty (e.g. by police at ...
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https://giaccentre.org/facilitation-payments/
In some cases, the facilitation payment may be forcibly extracted from personnel by real or perceived threats to safety or liberty (e.g. by police at ...
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13
Guidance: Facilitation Payments - Rolls-Royce
https://ourcode.rolls-royce.com/~/media/Files/R/Rolls-Royce-COC/documents/E%20and%20C%20Docs/Faciltation%20Payment%20Guidance_v20_final_PUBLIC.pdf
consider this extortion rather than a Facilitation Payment). In such cases, the employee should immediately inform a member of their business Ethics ...
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https://ourcode.rolls-royce.com/~/media/Files/R/Rolls-Royce-COC/documents/E%20and%20C%20Docs/Faciltation%20Payment%20Guidance_v20_final_PUBLIC.pdf
consider this extortion rather than a Facilitation Payment). In such cases, the employee should immediately inform a member of their business Ethics ...
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14
Corruption and Companies: The Use of Facilitating Payments
https://www.jstor.org/stable/25123578
although, as already mentioned, this is not always the case. Facilitating payments and the law. In most countries, the laws and regulations that govern public ...
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https://www.jstor.org/stable/25123578
although, as already mentioned, this is not always the case. Facilitating payments and the law. In most countries, the laws and regulations that govern public ...
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15
What Is a Facilitation Payment? Definition & Examples
https://www.freshbooks.com/en-gb/hub/payments/what-is-a-facilitation-payment
When accountants hear the term “facilitation payment” they may automatically classify it as a bribe. But the truth is, facilitation payments are legal in some ...
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https://www.freshbooks.com/en-gb/hub/payments/what-is-a-facilitation-payment
When accountants hear the term “facilitation payment” they may automatically classify it as a bribe. But the truth is, facilitation payments are legal in some ...
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16
The FCPA's “Facilitating Payments” Exception: Mostly Harmless
https://globalanticorruptionblog.com/2014/06/17/the-fcpas-facilitating-payments-exception-mostly-harmless/
Second, the U.S. Department of Justice has interpreted this language to make the exception, if anything, even narrower—in some cases securing ...
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https://globalanticorruptionblog.com/2014/06/17/the-fcpas-facilitating-payments-exception-mostly-harmless/
Second, the U.S. Department of Justice has interpreted this language to make the exception, if anything, even narrower—in some cases securing ...
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17
FCPA: Facilitating Payments v. Unlawful Bribes | Clifford Chance
https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2012/03/fcpa-facilitating-payments-v-unlawful-bribes.pdf
The facilitating payments exception of the ... facilitating payments are those made ... each case had to be taken on its own merits.6.
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https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2012/03/fcpa-facilitating-payments-v-unlawful-bribes.pdf
The facilitating payments exception of the ... facilitating payments are those made ... each case had to be taken on its own merits.6.
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18
Facilitation payments and New Zealand's anti-bribery laws
https://www.justice.govt.nz/assets/documents/publications/facilitation-payments-guide.pdf
While the Crimes Act draws a distinction between facilitation payments and bribes, New Zealand lacks case law on where exactly this line is drawn.
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https://www.justice.govt.nz/assets/documents/publications/facilitation-payments-guide.pdf
While the Crimes Act draws a distinction between facilitation payments and bribes, New Zealand lacks case law on where exactly this line is drawn.
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19
Bribery Act guidance - Serious Fraud Office
https://www.sfo.gov.uk/publications/guidance-policy-and-protocols/bribery-act-guidance/
A facilitation payment is a type of bribe and should be seen as such. A common example is where a government official is given money or goods to perform (or ...
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https://www.sfo.gov.uk/publications/guidance-policy-and-protocols/bribery-act-guidance/
A facilitation payment is a type of bribe and should be seen as such. A common example is where a government official is given money or goods to perform (or ...
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20
Payments that 'grease the rails' - Fraud Magazine
https://www.fraud-magazine.com/article.aspx?id=4294980870
However, the company was within the law when it paid the first fee under a “facilitation payment” (AKA “grease payment”) amendment to the law. This 1988 ...
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https://www.fraud-magazine.com/article.aspx?id=4294980870
However, the company was within the law when it paid the first fee under a “facilitation payment” (AKA “grease payment”) amendment to the law. This 1988 ...
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21
Corruption and companies: The case of ... - IDEAS/RePEc
https://ideas.repec.org/p/ebg/iesewp/d-0539.html
Facilitating payments are a very widespread form of corruption. They consist of small payments or gifts made to a person -a public official or an employee ...
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https://ideas.repec.org/p/ebg/iesewp/d-0539.html
Facilitating payments are a very widespread form of corruption. They consist of small payments or gifts made to a person -a public official or an employee ...
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22
Bribery & Corruption Laws and Regulations | Germany | GLI
https://www.globallegalinsights.com/practice-areas/bribery-and-corruption-laws-and-regulations/germany
Facilitation payments are also prohibited. Even small-value gifts and hospitality for public officials may constitute a criminal offence depending on the ...
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https://www.globallegalinsights.com/practice-areas/bribery-and-corruption-laws-and-regulations/germany
Facilitation payments are also prohibited. Even small-value gifts and hospitality for public officials may constitute a criminal offence depending on the ...
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23
Facilitating Payment Definition - Investopedia
https://www.investopedia.com/terms/f/facilitating-payment.asp
The company may make a facilitating payment to an official who can help “expedite” the licensing or permitting process. In many countries, this payment would be ...
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https://www.investopedia.com/terms/f/facilitating-payment.asp
The company may make a facilitating payment to an official who can help “expedite” the licensing or permitting process. In many countries, this payment would be ...
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24
What Is A Facilitation Payment? - DeltaNet International
https://www.delta-net.com/knowledge-base/compliance/customs-controls/what-is-a-facilitation-payment-2/
An example of a facilitation payment might be a business paying a customs official to release held goods. These held goods will generally be released anyway ...
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https://www.delta-net.com/knowledge-base/compliance/customs-controls/what-is-a-facilitation-payment-2/
An example of a facilitation payment might be a business paying a customs official to release held goods. These held goods will generally be released anyway ...
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25
The End of the FCPA Facilitation Payment Exception?
https://www.lexisnexis.com/legalnewsroom/securities/b/securities/posts/the-end-of-the-fcpa-facilitation-payment-exception
Facilitation payments, also known as "expediting payments" or "grease payments," are bribes paid to induce foreign officials to perform routine ...
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https://www.lexisnexis.com/legalnewsroom/securities/b/securities/posts/the-end-of-the-fcpa-facilitation-payment-exception
Facilitation payments, also known as "expediting payments" or "grease payments," are bribes paid to induce foreign officials to perform routine ...
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26
Facilitation payments – just say 'no' - Austrade
https://www.austrade.gov.au/ArticleDocuments/1358/Antibribery-Facilitation-Payments.pdf.aspx
Is there a distinction between a facilitation payment and a bribe? ... of a facilitation payment. Unfortunately, there is no Australian case law or guidance.
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https://www.austrade.gov.au/ArticleDocuments/1358/Antibribery-Facilitation-Payments.pdf.aspx
Is there a distinction between a facilitation payment and a bribe? ... of a facilitation payment. Unfortunately, there is no Australian case law or guidance.
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27
Bribery Act 2010: Facilitation payments | Practical Law - Westlaw
https://content.next.westlaw.com/practical-law/document/I28c1f832590011e598dc8b09b4f043e0/Bribery-Act-2010-Facilitation-payments?viewType=FullText&ppcid=8dfda5cb41b7459c99d8d1c827f521a6&originationContext=knowHow&transitionType=KnowHowItem&contextData=%28sc.DocLink%29
A facilitation payment is an unofficial, usually small payment made to foreign officials for the performance of routine actions. They are usually intended to ...
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https://content.next.westlaw.com/practical-law/document/I28c1f832590011e598dc8b09b4f043e0/Bribery-Act-2010-Facilitation-payments?viewType=FullText&ppcid=8dfda5cb41b7459c99d8d1c827f521a6&originationContext=knowHow&transitionType=KnowHowItem&contextData=%28sc.DocLink%29
A facilitation payment is an unofficial, usually small payment made to foreign officials for the performance of routine actions. They are usually intended to ...
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28
Examples of bribes or facilitation payments
https://www.londonpandi.com/knowledge/financial-crime/bribery-corruption/examples-of-bribes-or-facilitation-payments/
Examples of bribes or facilitation payments with public functions are included in the table below as these may be disguised as 'miscellaneous expenses' or ...
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https://www.londonpandi.com/knowledge/financial-crime/bribery-corruption/examples-of-bribes-or-facilitation-payments/
Examples of bribes or facilitation payments with public functions are included in the table below as these may be disguised as 'miscellaneous expenses' or ...
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29
RESIST - International Chamber of Commerce
https://iccwbo.org/content/uploads/sites/3/2016/11/RESIST-English.pdf
“Clean Business is Good Business – The Business Case against. Corruption”, jointly developed by the UN ... ically covers extortion and facilitation pay-.
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https://iccwbo.org/content/uploads/sites/3/2016/11/RESIST-English.pdf
“Clean Business is Good Business – The Business Case against. Corruption”, jointly developed by the UN ... ically covers extortion and facilitation pay-.
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30
What is a Facilitation Payment in the Bribery Act 2010?
https://www.stpaulschambers.com/what-is-a-facilitation-payment/
Facilitation payments, also known as 'grease payments', can be payments to officials in exchange for services. Typically, these services are a ...
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https://www.stpaulschambers.com/what-is-a-facilitation-payment/
Facilitation payments, also known as 'grease payments', can be payments to officials in exchange for services. Typically, these services are a ...
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31
Customs Corruption Risks: Should a Company Ever Pay a ...
https://www.anti-corruption.com/2569376/customs-corruption-risks-should-a-company-ever-pay-a-facilitation-payment-to-a-customs-official-part-three-of-three.thtml
This article, the final installment of the Anti-Corruption Report's series on anti-corruption risks related to customs, takes an in-depth look at facilitation ...
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https://www.anti-corruption.com/2569376/customs-corruption-risks-should-a-company-ever-pay-a-facilitation-payment-to-a-customs-official-part-three-of-three.thtml
This article, the final installment of the Anti-Corruption Report's series on anti-corruption risks related to customs, takes an in-depth look at facilitation ...
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32
Facilitation Payments: A Crime?
https://www.zis-online.com/dat/artikel/2015_9_948.pdf
ery of Foreign Public Officials exempt facilitation payments ... ery of a foreign public official solely in cases, in which an.
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https://www.zis-online.com/dat/artikel/2015_9_948.pdf
ery of Foreign Public Officials exempt facilitation payments ... ery of a foreign public official solely in cases, in which an.
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33
Chapter 7 - Parliament of Australia
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Economics/Foreignbribery45th/Report/c07b
7.1 A facilitation payment is a minor payment made to a foreign public official for the purpose of speeding up minor routine government action.[1] Such a ...
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https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Economics/Foreignbribery45th/Report/c07b
7.1 A facilitation payment is a minor payment made to a foreign public official for the purpose of speeding up minor routine government action.[1] Such a ...
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34
Code of Ethics | Atos
https://atos.net/wp-content/uploads/2021/04/atos-code-of-ethics-mar-2021.pdf
encouraged to speak up in case of legitimate reasons to believe the standards in our Code of ... facilitation payments and all other forms of corruption,.
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https://atos.net/wp-content/uploads/2021/04/atos-code-of-ethics-mar-2021.pdf
encouraged to speak up in case of legitimate reasons to believe the standards in our Code of ... facilitation payments and all other forms of corruption,.
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35
Facilitation Payments: Are They Legal Bribery?
https://blog.volkovlaw.com/2012/07/facilitation-payments-are-they-legal-bribery/
Under the FCPA's exception for facilitation payments, can you in good faith reach a decision to pay the “fee.” In most cases “yes;” but in some ...
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https://blog.volkovlaw.com/2012/07/facilitation-payments-are-they-legal-bribery/
Under the FCPA's exception for facilitation payments, can you in good faith reach a decision to pay the “fee.” In most cases “yes;” but in some ...
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36
I have been asked to pay - DWR - Stora Enso
https://dwr.storaenso.com/dwr-i-have-been-asked-to-pay/
A fee is the price one pays as remuneration for services. However, “unofficial fees” can be a form of hidden corruption or in some cases seen as facilitation ...
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https://dwr.storaenso.com/dwr-i-have-been-asked-to-pay/
A fee is the price one pays as remuneration for services. However, “unofficial fees” can be a form of hidden corruption or in some cases seen as facilitation ...
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37
Case Example: Coca-Cola's fight against corruption in Myanmar
https://www.unglobalcompact.org/take-action/action/case-example/113
The card clarifies that the drivers will be required to report to the management as any such bribes or facilitation payments will be a violation of ...
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https://www.unglobalcompact.org/take-action/action/case-example/113
The card clarifies that the drivers will be required to report to the management as any such bribes or facilitation payments will be a violation of ...
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38
Business ethics and anti-corruption laws: Japan
https://www.nortonrosefulbright.com/en/knowledge/publications/3311d00d/business-ethics-and-anti-corruption-laws-japan
The UCPA does not expressly allow citizens to give facilitation payments. However, under limited circumstances, there may be cases where such payment is not ...
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https://www.nortonrosefulbright.com/en/knowledge/publications/3311d00d/business-ethics-and-anti-corruption-laws-japan
The UCPA does not expressly allow citizens to give facilitation payments. However, under limited circumstances, there may be cases where such payment is not ...
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39
The Foreign Corrupt Practices Act: Compliance Issues in the ...
https://www.millerchevalier.com/sites/default/files/news_updates/attached_files/tei205batkinson20tillen5d.pdf
thus, fell within the statutory exception for “facilitation” ... In a pair of cases in 2001, payments to reduce tax as- sessments in Indonesia again created ...
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https://www.millerchevalier.com/sites/default/files/news_updates/attached_files/tei205batkinson20tillen5d.pdf
thus, fell within the statutory exception for “facilitation” ... In a pair of cases in 2001, payments to reduce tax as- sessments in Indonesia again created ...
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40
Facilitation payments - Attorney-General's Department
https://www.ag.gov.au/crime/foreign-bribery/facilitation-payments
Such payments represent a serious business risk and are difficult to distinguish from bribes. The facilitation payment defence may not be available under the ...
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https://www.ag.gov.au/crime/foreign-bribery/facilitation-payments
Such payments represent a serious business risk and are difficult to distinguish from bribes. The facilitation payment defence may not be available under the ...
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41
Anti-Bribery & Corruption Policy | GSK
https://www.gsk.com/media/2976/anti-bribery-and-corruption-policy-v15.pdf
We prohibit all facilitation payments as they are bribes. ... In case of disagreement regarding the government official status of a person, Legal.
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https://www.gsk.com/media/2976/anti-bribery-and-corruption-policy-v15.pdf
We prohibit all facilitation payments as they are bribes. ... In case of disagreement regarding the government official status of a person, Legal.
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42
United States - Global bribery offenses guide | | Insights
https://www.dlapiper.com/en/us/insights/publications/2019/09/bribery-offenses-guide/united-states/
US authorities have held companies responsible for FCPA violations in a variety of cases, including where bribes were allegedly paid in exchange ...
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https://www.dlapiper.com/en/us/insights/publications/2019/09/bribery-offenses-guide/united-states/
US authorities have held companies responsible for FCPA violations in a variety of cases, including where bribes were allegedly paid in exchange ...
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43
Facilitation Payment in a Bribery Case - Doogue + George
https://www.criminal-lawyers.com.au/corporate-crime/facilitation-payments
In essence, a facilitation payment is a small payment that is not a bribe. It needs to be recorded as soon as practicable. It does not cover actions taken ...
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https://www.criminal-lawyers.com.au/corporate-crime/facilitation-payments
In essence, a facilitation payment is a small payment that is not a bribe. It needs to be recorded as soon as practicable. It does not cover actions taken ...
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44
Digging into Facilitation Payments | Stikeman Elliott
https://www.stikeman.com/fr-ca/savoir/droit-minier-canadien/digging-into-facilitation-payments
Since the CFPOA's enactment in 1999, the facilitation payment exception has provided a safe harbour for certain types of payment made to foreign public ...
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https://www.stikeman.com/fr-ca/savoir/droit-minier-canadien/digging-into-facilitation-payments
Since the CFPOA's enactment in 1999, the facilitation payment exception has provided a safe harbour for certain types of payment made to foreign public ...
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45
Corruption and Companies: The Case of Facilitating Payments
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=685861
Facilitating payments are a very widespread form of corruption. They consist of small payments or gifts made to a person - a public official or ...
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https://papers.ssrn.com/sol3/papers.cfm?abstract_id=685861
Facilitating payments are a very widespread form of corruption. They consist of small payments or gifts made to a person - a public official or ...
→ Check Latest Keyword Rankings ←
46
Anti-Corruption in France - Global Compliance News
https://www.globalcompliancenews.com/anti-corruption/handbook/anti-corruption-in-france/
Facilitation payments must therefore be analyzed on a case-by-case basis, as previously described, followiThe French Criminal Code does not recognize so-called ...
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https://www.globalcompliancenews.com/anti-corruption/handbook/anti-corruption-in-france/
Facilitation payments must therefore be analyzed on a case-by-case basis, as previously described, followiThe French Criminal Code does not recognize so-called ...
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47
Facilitation Payments Still Permitted Under FCPA
https://www.roanokegroup.com/blog/facilitation-payments-still-permitted-under-fcpa/
“Facilitation payments” made to customs officers are common in some parts of the world, and, strictly speaking, they don't violate the U.S. Foreign Corrupt ...
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https://www.roanokegroup.com/blog/facilitation-payments-still-permitted-under-fcpa/
“Facilitation payments” made to customs officers are common in some parts of the world, and, strictly speaking, they don't violate the U.S. Foreign Corrupt ...
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48
Facilitation Payment Abolishment in Australia Report - Ivypanda
https://ivypanda.com/essays/facilitation-payment-abolishment-in-australia/
In case these sums of money are paid, this does not imply that the Australian businesses get given advantages over other businesses such as ...
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https://ivypanda.com/essays/facilitation-payment-abolishment-in-australia/
In case these sums of money are paid, this does not imply that the Australian businesses get given advantages over other businesses such as ...
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49
POLICY ON EXTORTION AND PROHIBITION OF ... - Aegea
https://www.aegea.com.br/wp-content/uploads/2020/11/DO005-GIT99-POLICY-ON-EXTORTION-AND-PROHIBITION-OF-FACILITATION-PAYMENTS.pdf
POLICY ON EXTORTION AND PROHIBITION. OF FACILITATION PAYMENTS ... HOW TO ACT IN CASE OF A REQUEST FOR FACILITATION PAYMENT ............................ 4.
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https://www.aegea.com.br/wp-content/uploads/2020/11/DO005-GIT99-POLICY-ON-EXTORTION-AND-PROHIBITION-OF-FACILITATION-PAYMENTS.pdf
POLICY ON EXTORTION AND PROHIBITION. OF FACILITATION PAYMENTS ... HOW TO ACT IN CASE OF A REQUEST FOR FACILITATION PAYMENT ............................ 4.
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50
foreign corrupt practices act - Office of the General Counsel
https://ogc.princeton.edu/sites/ogc/files/media/508_fcpa_faqs.pdf
One of those exceptions is referred to as “facilitation payments” – these are payments to a ... In this case, (1) and (2) seems to be.
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https://ogc.princeton.edu/sites/ogc/files/media/508_fcpa_faqs.pdf
One of those exceptions is referred to as “facilitation payments” – these are payments to a ... In this case, (1) and (2) seems to be.
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51
Anti-Corruption Ethics and Compliance Handbook for Business
https://www.oecd.org/corruption/Anti-CorruptionEthicsComplianceHandbook.pdf
Annex 2: Sample Compliance Assessment Checklist (From Section C.12, Case Study 1) . ... Corruption and bribery (including a ban on facilitation payments);.
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https://www.oecd.org/corruption/Anti-CorruptionEthicsComplianceHandbook.pdf
Annex 2: Sample Compliance Assessment Checklist (From Section C.12, Case Study 1) . ... Corruption and bribery (including a ban on facilitation payments);.
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52
Anti-Bribery Policy | The Coca-Cola Company
https://www.coca-colacompany.com/policies-and-practices/anti-bribery-policy
4.2.3. Facilitation Payments - The Company's prohibition on bribery applies to all improper payments regardless of size or purpose, including “facilitating” (or ...
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https://www.coca-colacompany.com/policies-and-practices/anti-bribery-policy
4.2.3. Facilitation Payments - The Company's prohibition on bribery applies to all improper payments regardless of size or purpose, including “facilitating” (or ...
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53
Supply chain delays and facilitation payments: a timely reminder
https://viewpoints.reedsmith.com/post/102hret/supply-chain-delays-and-facilitation-payments-a-timely-reminder
Facilitation payments are nominal, unofficial payments to secure or expedite the performance of a routine, non-discretionary government ...
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https://viewpoints.reedsmith.com/post/102hret/supply-chain-delays-and-facilitation-payments-a-timely-reminder
Facilitation payments are nominal, unofficial payments to secure or expedite the performance of a routine, non-discretionary government ...
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54
Shallow Commentary Regarding The Facilitation Payments ...
https://fcpaprofessor.com/shallow-commentary-regarding-facilitation-payments-exception/
the defendants argued that the SEC had the burden of pleading the inapplicability of the facilitating payments exception, whereas the SEC argued ...
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https://fcpaprofessor.com/shallow-commentary-regarding-facilitation-payments-exception/
the defendants argued that the SEC had the burden of pleading the inapplicability of the facilitating payments exception, whereas the SEC argued ...
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55
Anti-Bribery Principle - 3M
https://multimedia.3m.com/mws/media/459284O/anti-bribery-principle.pdf
offer or accept bribes, kickbacks, corrupt payments, facilitation ... In such cases, close relatives of that Government Official may be hired only if:.
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https://multimedia.3m.com/mws/media/459284O/anti-bribery-principle.pdf
offer or accept bribes, kickbacks, corrupt payments, facilitation ... In such cases, close relatives of that Government Official may be hired only if:.
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56
UK Serious Fraud Office Revises Guidance on Facilitation ...
https://www.gibsondunn.com/uk-serious-fraud-office-revises-guidance-on-facilitation-payments-and-corporate-hospitality-under-the-bribery-act-and-on-self-reporting-of-misconduct/
Actual examples of prosecutions for facilitation payments are difficult to identify, barring one prosecution, dating from the 1970s, for a £4 ...
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https://www.gibsondunn.com/uk-serious-fraud-office-revises-guidance-on-facilitation-payments-and-corporate-hospitality-under-the-bribery-act-and-on-self-reporting-of-misconduct/
Actual examples of prosecutions for facilitation payments are difficult to identify, barring one prosecution, dating from the 1970s, for a £4 ...
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57
Anti-Bribery and Corruption Compliance Policy and ...
https://www.teck.com/media/Anti-Bribery-and-Corruption-Compliance-Policy-and-Interpretation-Guide.pdf
B. Facilitation Payments Are Not Permitted . ... Regional Compliance Coordinator in the case of donations outside North America.
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https://www.teck.com/media/Anti-Bribery-and-Corruption-Compliance-Policy-and-Interpretation-Guide.pdf
B. Facilitation Payments Are Not Permitted . ... Regional Compliance Coordinator in the case of donations outside North America.
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58
What Is a Facilitation Payment Definition - Vicantres
https://vicantres.com/what-is-a-facilitation-payment-definition
«facilitation payment» means the term often given to an illegal or unofficial payment in exchange for services to which the payer is legally entitled without ...
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https://vicantres.com/what-is-a-facilitation-payment-definition
«facilitation payment» means the term often given to an illegal or unofficial payment in exchange for services to which the payer is legally entitled without ...
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59
1011 - U.S. Foreign Corrupt Practices Act (FCPA) Policy
https://humanresources.uchicago.edu/fpg/policies/1000/p1011.shtml
“Facilitating” payments to Foreign Officials (i.e., payments that increase the speed at which Foreign Officials perform their functions) are permitted under ...
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https://humanresources.uchicago.edu/fpg/policies/1000/p1011.shtml
“Facilitating” payments to Foreign Officials (i.e., payments that increase the speed at which Foreign Officials perform their functions) are permitted under ...
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60
The Bribery Act 2010 - Guidance - Justice.gov.uk
https://www.justice.gov.uk/downloads/legislation/bribery-act-2010-guidance.pdf
Note also the common law 'identification principle' as defined by cases such as Tesco Supermarkets v ... eradication of facilitation payments.
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https://www.justice.gov.uk/downloads/legislation/bribery-act-2010-guidance.pdf
Note also the common law 'identification principle' as defined by cases such as Tesco Supermarkets v ... eradication of facilitation payments.
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61
guidance: facilitation payments - LSE
https://info.lse.ac.uk/staff/divisions/Secretarys-Division/Assets/Documents/Ethics/Facilitation-payments-guidance-v2.pdf
UK Bribery Act guidance recognises that payments may be made 'in order to protect against loss of life, limb or liberty'. In such cases where payment is ...
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https://info.lse.ac.uk/staff/divisions/Secretarys-Division/Assets/Documents/Ethics/Facilitation-payments-guidance-v2.pdf
UK Bribery Act guidance recognises that payments may be made 'in order to protect against loss of life, limb or liberty'. In such cases where payment is ...
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62
BBC GUIDANCE – FACILITATION PAYMENTS How to resist ...
http://downloads.bbc.co.uk/commissioning/site/Facilitation_payments_guidance_13July2011.pdf
Our zero-tolerance approach to bribery in the case of facilitation payments involves a policy of resistance which is achieved in stages.
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http://downloads.bbc.co.uk/commissioning/site/Facilitation_payments_guidance_13July2011.pdf
Our zero-tolerance approach to bribery in the case of facilitation payments involves a policy of resistance which is achieved in stages.
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63
Anti-Bribery and Corruption Policy - NYU
https://www.nyu.edu/about/policies-guidelines-compliance/policies-and-guidelines/anti-bribery-and-corruption-policy.html
Facilitating payments are not permissible under this policy other than as specified ... services is not a prohibited facilitating payment (in such cases, ...
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https://www.nyu.edu/about/policies-guidelines-compliance/policies-and-guidelines/anti-bribery-and-corruption-policy.html
Facilitating payments are not permissible under this policy other than as specified ... services is not a prohibited facilitating payment (in such cases, ...
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64
Ethics of 'facilitation payments' pit business principles against ...
https://mlexmarketinsight.com/news-hub/editors-picks/area-of-expertise/anti-bribery-and-corruption/ethics-of-facilitation-payments-pit-business-principles-against-practicalities-in-the-developing-world
Under existing Australian foreign bribery laws, companies can use the “facilitation payment” defense to justify giving money to foreign ...
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https://mlexmarketinsight.com/news-hub/editors-picks/area-of-expertise/anti-bribery-and-corruption/ethics-of-facilitation-payments-pit-business-principles-against-practicalities-in-the-developing-world
Under existing Australian foreign bribery laws, companies can use the “facilitation payment” defense to justify giving money to foreign ...
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65
What about facilitation payments?
https://www.cms-lawnow.com/aczone/bribery/faqs-on-adequate-procedures/what-about-facilitation-payments
However, while facilitation payments are technically illegal, it does not follow that their payment will be prosecuted in every case.
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https://www.cms-lawnow.com/aczone/bribery/faqs-on-adequate-procedures/what-about-facilitation-payments
However, while facilitation payments are technically illegal, it does not follow that their payment will be prosecuted in every case.
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66
The Foreign Corrupt Practices Act: Taking A Bite Out Of ...
https://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?article=1305&context=jcfl
describe bribery and FCPA case filings, sanctions, payments. (bribes), and value of business to be obtained; ... Facilitating or Expediting Payments.
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https://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?article=1305&context=jcfl
describe bribery and FCPA case filings, sanctions, payments. (bribes), and value of business to be obtained; ... Facilitating or Expediting Payments.
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67
1551—The United States Foreign Corrupt Practices Act
https://www2.deloitte.com/content/dam/Deloitte/co/Documents/Pol%C3%ADticas/DPM%201551%20The%20United%20States%20Foreign%20Corrupt%20Practices%20Act.pdf
Should not make any Facilitation Payment except in rare ... General Counsel; and (b), in the case of a U.S. Prime Covered Engagement, with.
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https://www2.deloitte.com/content/dam/Deloitte/co/Documents/Pol%C3%ADticas/DPM%201551%20The%20United%20States%20Foreign%20Corrupt%20Practices%20Act.pdf
Should not make any Facilitation Payment except in rare ... General Counsel; and (b), in the case of a U.S. Prime Covered Engagement, with.
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68
Anti-Bribery and Corruption Policy - Olam Group
https://www.olamgroup.com/content/dam/olamgroup/about-olam/ethics-and-compliance/ethics-and-compliance-pdfs/Olam-Anti-Bribery-and-Corruption-Policy-Aug2020.pdf
Examples of facilitation payments are set out in Appendix II. ... In certain cases, heightened due diligence may be required. Circumstances.
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https://www.olamgroup.com/content/dam/olamgroup/about-olam/ethics-and-compliance/ethics-and-compliance-pdfs/Olam-Anti-Bribery-and-Corruption-Policy-Aug2020.pdf
Examples of facilitation payments are set out in Appendix II. ... In certain cases, heightened due diligence may be required. Circumstances.
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69
CPS-730, Compliance with Anti-Corruption Laws
https://www.lockheedmartin.com/content/dam/lockheed-martin/eo/documents/ethics/cps-730.pdf
Any facilitating payments or personal safety payments; and ... in the case of a joint venture or teaming agreement, a requirement for the entity to.
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https://www.lockheedmartin.com/content/dam/lockheed-martin/eo/documents/ethics/cps-730.pdf
Any facilitating payments or personal safety payments; and ... in the case of a joint venture or teaming agreement, a requirement for the entity to.
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70
Case studies | Compliance - University of Oxford
https://compliance.admin.ox.ac.uk/case-studies
This may work – but not if the supervisor is also involved. If you are reasonably certain that this is a facilitation payment you need to explain why you cannot ...
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https://compliance.admin.ox.ac.uk/case-studies
This may work – but not if the supervisor is also involved. If you are reasonably certain that this is a facilitation payment you need to explain why you cannot ...
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71
Facilitation Payments: Facilitating Poverty? - Grant Follett, 2015
https://journals.sagepub.com/doi/abs/10.1177/1037969X1504000213
References ; 58. Joint Standing Committee on Treaties, above n11, [9.71]. Google Scholar ; 59. Argandona, Antonio , Corruption and Companies: The Case of ...
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https://journals.sagepub.com/doi/abs/10.1177/1037969X1504000213
References ; 58. Joint Standing Committee on Treaties, above n11, [9.71]. Google Scholar ; 59. Argandona, Antonio , Corruption and Companies: The Case of ...
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72
code-governing-the-fight-against-corruption-and-influence ...
https://www.societegenerale.com/sites/default/files/documents/Code%20de%20conduite/code-governing-the-fight-against-corruption-and-influence-peddling-uk.pdf
Facilitation payments 14 ... In certain cases, Societe Generale ... of the cases you could be faced with in the course of carrying out your professional ...
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https://www.societegenerale.com/sites/default/files/documents/Code%20de%20conduite/code-governing-the-fight-against-corruption-and-influence-peddling-uk.pdf
Facilitation payments 14 ... In certain cases, Societe Generale ... of the cases you could be faced with in the course of carrying out your professional ...
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73
The Anti-Bribery and Anti-Corruption Review: United Kingdom
https://thelawreviews.co.uk/title/the-anti-bribery-and-anti-corruption-review/united-kingdom-england--wales
Examples of cases conducted by the CPS include the prosecution of corrupt ... Facilitation payments are considered bribes under the Bribery ...
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https://thelawreviews.co.uk/title/the-anti-bribery-and-anti-corruption-review/united-kingdom-england--wales
Examples of cases conducted by the CPS include the prosecution of corrupt ... Facilitation payments are considered bribes under the Bribery ...
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74
COUNTERING SMALL BRIBES
https://www.transparency.nl/wp-content/uploads/2016/12/Countering_Small_Bribes.pdf
Effective countering of small bribes - including facilitation payments - will ... Case studies, scenarios, dilemmas and red flags can be used in training, ...
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https://www.transparency.nl/wp-content/uploads/2016/12/Countering_Small_Bribes.pdf
Effective countering of small bribes - including facilitation payments - will ... Case studies, scenarios, dilemmas and red flags can be used in training, ...
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75
Affirmative Defense: Promotional or Contract-Related Expenses
https://complianceconcourse.willkie.com/resources/anti-bribery-and-corruption-us-affirmative-defense-promotional-expenses
Reasonable expenditures are those that are not extreme or excessive. This is a fact-intensive inquiry determined on a case-by-case basis, often with reference ...
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https://complianceconcourse.willkie.com/resources/anti-bribery-and-corruption-us-affirmative-defense-promotional-expenses
Reasonable expenditures are those that are not extreme or excessive. This is a fact-intensive inquiry determined on a case-by-case basis, often with reference ...
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76
News From Down Under: The Case Against Leighton ...
https://www.natlawreview.com/article/news-down-under-case-against-leighton-holdings-further-highlights-problems-facilitat
Australia has made efforts to raise awareness of the facilitation payment defence, including through its proactive consultation process.
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https://www.natlawreview.com/article/news-down-under-case-against-leighton-holdings-further-highlights-problems-facilitat
Australia has made efforts to raise awareness of the facilitation payment defence, including through its proactive consultation process.
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77
Case stories and examples - Export Development Canada
https://www.edc.ca/content/dam/edc/en/non-premium/BACbookFINAL.pdf
Case.story:.The.corporate.ethics.framework—A.road.to.fighting.corruption. . . . . . . 62. Richard Lanaud | Total. IV .. Facilitation.payments.
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https://www.edc.ca/content/dam/edc/en/non-premium/BACbookFINAL.pdf
Case.story:.The.corporate.ethics.framework—A.road.to.fighting.corruption. . . . . . . 62. Richard Lanaud | Total. IV .. Facilitation.payments.
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78
The Foreign Corrupt Practices Act: An Overview - Jones Day
https://www.jonesday.com/en/insights/2010/01/the-foreign-corrupt-practices-act-an-overview
Facilitating Payments for Routine Government Actions. The FCPA does not prohibit "facilitating or expediting payment[s]" made to foreign officials for the ...
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https://www.jonesday.com/en/insights/2010/01/the-foreign-corrupt-practices-act-an-overview
Facilitating Payments for Routine Government Actions. The FCPA does not prohibit "facilitating or expediting payment[s]" made to foreign officials for the ...
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79
Australia: Global trend in facilitation payments law ... - Mondaq
https://www.mondaq.com/australia/white-collar-crime-anti-corruption-fraud/294822/global-trend-in-facilitation-payments-law-implications-for-companies-in-asia-pacific
Facilitation payments, also known as "grease payments" are low value payments designed to speed up routine government actions.
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https://www.mondaq.com/australia/white-collar-crime-anti-corruption-fraud/294822/global-trend-in-facilitation-payments-law-implications-for-companies-in-asia-pacific
Facilitation payments, also known as "grease payments" are low value payments designed to speed up routine government actions.
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80
Payfacs: A guide to payment facilitation - Stripe
https://stripe.com/guides/payfacs
Use our guide to payment facilitation to learn about payfacs and how to bring ... If you'd like to talk to our team about your specific use case and ...
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https://stripe.com/guides/payfacs
Use our guide to payment facilitation to learn about payfacs and how to bring ... If you'd like to talk to our team about your specific use case and ...
→ Check Latest Keyword Rankings ←
81
U.S. Foreign Corrupt Practices Act (FCPA) - Case Study - aabri
https://www.aabri.com/manuscripts/193148.pdf
be facilitating any payments of bribes either directly or indirectly. • Be wary of paying rebates, discounts, and refunds as they are often vehicles of bribery.
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https://www.aabri.com/manuscripts/193148.pdf
be facilitating any payments of bribes either directly or indirectly. • Be wary of paying rebates, discounts, and refunds as they are often vehicles of bribery.
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82
STANDARD GUIDANCE (COP 9) Bribery and Facilitation ...
https://www.responsiblejewellery.com/files/Bribery-and-Facilitation-Payments-RJC-Guidance-draftv1.pdf
In other cases, a bribe may be effectively extracted from the person paying. Facilitation payments have historically attracted a more mixed response.
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https://www.responsiblejewellery.com/files/Bribery-and-Facilitation-Payments-RJC-Guidance-draftv1.pdf
In other cases, a bribe may be effectively extracted from the person paying. Facilitation payments have historically attracted a more mixed response.
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83
Family Law Facilitators - Skagit County
https://www.skagitcounty.net/Departments/SuperiorCourt/familylaw.htm
Follow instructions to pay $20.00 for appointment fee and put confirmation number on Disclaimer. PAYMENTS. If you do not know your case number, you can find it ...
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https://www.skagitcounty.net/Departments/SuperiorCourt/familylaw.htm
Follow instructions to pay $20.00 for appointment fee and put confirmation number on Disclaimer. PAYMENTS. If you do not know your case number, you can find it ...
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84
ANTI-CORRUPTION AND FACILITATION PAYMENTS Sample ...
https://www.lawinsider.com/clause/anti-corruption-and-facilitation-payments
ANTI-CORRUPTION AND FACILITATION PAYMENTS a) Buyer and the Seller shall ... for political office, in each case in violation of the Anti-Bribery Laws.
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https://www.lawinsider.com/clause/anti-corruption-and-facilitation-payments
ANTI-CORRUPTION AND FACILITATION PAYMENTS a) Buyer and the Seller shall ... for political office, in each case in violation of the Anti-Bribery Laws.
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85
Code of Conduct and Anti-Corruption Policy | Teleperformance
https://www.teleperformance.com/en-us/codes-and-policies/code-of-conduct-anticorruption/
Facilitation Payment is a form of Corruption in which money is paid, ... In all cases, you must keep a written record specifying the type of gift or ...
→ Check Latest Keyword Rankings ←
https://www.teleperformance.com/en-us/codes-and-policies/code-of-conduct-anticorruption/
Facilitation Payment is a form of Corruption in which money is paid, ... In all cases, you must keep a written record specifying the type of gift or ...
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86
ANTI BRIBERY AND CORRUPTION POLICY FOR THIRD ...
https://www.think-gas.com/admin/wp-content/uploads/2019/12/ANTI-BRIBERY-AND-CORRUPTION-POLICY-FOR-THIRD-PARTY.pdf
Facilitation payments are made for the purpose of expediting or facilitating the ... In all cases, expenditures must be reasonable and directly related to a ...
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https://www.think-gas.com/admin/wp-content/uploads/2019/12/ANTI-BRIBERY-AND-CORRUPTION-POLICY-FOR-THIRD-PARTY.pdf
Facilitation payments are made for the purpose of expediting or facilitating the ... In all cases, expenditures must be reasonable and directly related to a ...
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87
Facilitation payments - Stop paying and they stop asking
https://www.reutersevents.com/sustainability/content/facilitation-payments-stop-paying-and-they-stop-asking
The most pervasive kind of small bribes are facilitation payments – or money paid to local officials to accelerate bureaucratic procedures.
→ Check Latest Keyword Rankings ←
https://www.reutersevents.com/sustainability/content/facilitation-payments-stop-paying-and-they-stop-asking
The most pervasive kind of small bribes are facilitation payments – or money paid to local officials to accelerate bureaucratic procedures.
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88
Facilitating the End of Facilitation Payments | Cassels.com
https://cassels.com/insights/facilitating-the-end-of-facilitation-payments/
The Canadian government has eliminated the exception allowing for facilitation payments under Canada's anti-corruption regime effective October 31, 2017.
→ Check Latest Keyword Rankings ←
https://cassels.com/insights/facilitating-the-end-of-facilitation-payments/
The Canadian government has eliminated the exception allowing for facilitation payments under Canada's anti-corruption regime effective October 31, 2017.
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89
Payment Facilitation - What you should know about SaaS as ...
https://www.agilepayments.com/payment-facilitation
Another option? Payment Facilitation providers. What to look for in a partner; Payment Facilitator versus MarketPlace Payments; Case Study; Next steps ...
→ Check Latest Keyword Rankings ←
https://www.agilepayments.com/payment-facilitation
Another option? Payment Facilitation providers. What to look for in a partner; Payment Facilitator versus MarketPlace Payments; Case Study; Next steps ...
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90
Facilitation Payments Now Illegal Under Canada's Foreign ...
https://www.mccarthy.ca/en/insights/blogs/terms-trade/facilitation-payments-now-illegal-under-canadas-foreign-corruption-law
Facilitation Payments Now Illegal Under Canada's Foreign Corruption Law ... On October 31, 2017, the federal government brought into force a pending ...
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https://www.mccarthy.ca/en/insights/blogs/terms-trade/facilitation-payments-now-illegal-under-canadas-foreign-corruption-law
Facilitation Payments Now Illegal Under Canada's Foreign Corruption Law ... On October 31, 2017, the federal government brought into force a pending ...
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91
New UK Bribery Act Guidance Covers Facilitation Payments ...
https://jenner.com/system/assets/publications/10891/original/New_UK_Bribery_Act_Guidance_Covers_Facilitation_Payments_Self-reporting_10-12.pdf?1364805949
facilitation payments, although such payments will be prosecuted only if the evidence and the ... that self-reported cases would be resolved.
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https://jenner.com/system/assets/publications/10891/original/New_UK_Bribery_Act_Guidance_Covers_Facilitation_Payments_Self-reporting_10-12.pdf?1364805949
facilitation payments, although such payments will be prosecuted only if the evidence and the ... that self-reported cases would be resolved.
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92
Glossary - U4 Anti-Corruption Resource Centre
https://www.u4.no/terms
In these cases, corruption is the norm and not the exception. ... In many countries, however, facilitation payments by companies doing business abroad are ...
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https://www.u4.no/terms
In these cases, corruption is the norm and not the exception. ... In many countries, however, facilitation payments by companies doing business abroad are ...
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93
Blurred Lines: The Foreign Corrupt Practices Act, Bribes and ...
https://www.law.com/corpcounsel/2020/10/28/blurred-lines-the-foreign-corrupt-practices-act-bribes-and-facilitation-payments/
Blurred Lines: The Foreign Corrupt Practices Act, Bribes and Facilitation Payments ... For companies doing business on a global scale, the ...
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https://www.law.com/corpcounsel/2020/10/28/blurred-lines-the-foreign-corrupt-practices-act-bribes-and-facilitation-payments/
Blurred Lines: The Foreign Corrupt Practices Act, Bribes and Facilitation Payments ... For companies doing business on a global scale, the ...
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94
Anti-Bribery Policy
https://s23.q4cdn.com/712438926/files/doc_downloads/governance/Anti-Bribery-Policy.pdf
foreign bribery that may not exempt facilitation payments (see discussion ... must be followed in all cases, with particular attention to “red flags” that ...
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https://s23.q4cdn.com/712438926/files/doc_downloads/governance/Anti-Bribery-Policy.pdf
foreign bribery that may not exempt facilitation payments (see discussion ... must be followed in all cases, with particular attention to “red flags” that ...
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95
Anti-bribery Code of Conduct - Biesse Group
https://www.biessegroup.com/media/files/1403_Antibribery%20Code%20of%20Conduct.pdf
Facilitation Payment: unofficial payments made to a Public Officer, with the ... case, Biesse prohibits Facilitation Payments in any part of the world and, ...
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https://www.biessegroup.com/media/files/1403_Antibribery%20Code%20of%20Conduct.pdf
Facilitation Payment: unofficial payments made to a Public Officer, with the ... case, Biesse prohibits Facilitation Payments in any part of the world and, ...
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96
Global Integrity Policy Gifts, Entertainment and Anti-Corruption
https://investor.gm.com/static-files/d8e937d5-c352-4d13-8488-5c0891e7e4ad
Exceptions to this Policy may be granted by the GECC on a case-specific basis, ... corrupt payments, immediately report this to the GECC, GM Awareline or ...
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https://investor.gm.com/static-files/d8e937d5-c352-4d13-8488-5c0891e7e4ad
Exceptions to this Policy may be granted by the GECC on a case-specific basis, ... corrupt payments, immediately report this to the GECC, GM Awareline or ...
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97
Anti-Bribery and Anti- Corruption Policy - Control Risks
https://www.controlrisks.com/-/media/corporate/files/who-we-are/corporate-responsibility/anti-bribery-and-anti-corruption-policy-v1_6.pdf?la=en&hash=4060E49BBBDEA6F1DA3C3F1E6F01F9E22E19ED78
However, if that's not the case please use the Control Risks ... Corruption can include graft, bribery, facilitation payments or other forms of improper.
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https://www.controlrisks.com/-/media/corporate/files/who-we-are/corporate-responsibility/anti-bribery-and-anti-corruption-policy-v1_6.pdf?la=en&hash=4060E49BBBDEA6F1DA3C3F1E6F01F9E22E19ED78
However, if that's not the case please use the Control Risks ... Corruption can include graft, bribery, facilitation payments or other forms of improper.
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98
New UK Guidance on Coping with Small Bribes and ...
https://www.bclplaw.com/a/web/2199/Bulletin-Countering-small-bribes-July-2014.pdf
requests for small bribes, including facilitation payments (also known as ... a section on assessing risk, practical examples and case studies, model.
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https://www.bclplaw.com/a/web/2199/Bulletin-Countering-small-bribes-July-2014.pdf
requests for small bribes, including facilitation payments (also known as ... a section on assessing risk, practical examples and case studies, model.
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