 to make a payment to a foreign official for the purpose of obtaining or retaining business for or with, or directing business to, any person. Since the 1998 Amendment of FCPA they also apply to foreign firms and persons who take any act in furtherance of such a corrupt payment while in the U.S. the meaning of foreign official is broad. For example, an owner of a bank who is also the minister of finance would count as a foreign official according to the U.S. government. Doctors at government-owned or managed hospitals are also considered to be foreign officials under the FCPA, as is anyone working for a government-owned or managed institution or enterprise. Employees of international organizations such as the United Nations are also considered to be foreign officials under the FCPA. A 2014 federal appellate court decision has provided guidance on how the term "foreign official" is defined under FCPA.

Because the Act concerns the intent of the bribery rather than the amount, there is no requirement of materiality. Offering anything of value as a bribe, whether cash or non-cash items, is prohibited.

The FCPA also requires companies whose securities are listed in the U.S. to meet its accounting provisions. These accounting provisions operate in tandem with the anti-bribery provisions of the FCPA, and require respective corporations to make and keep books and records that accurately and fairly reflect the transactions of the corporation and to devise and maintain an adequate system of internal accounting controls. An increasing number of corporations are taking additional steps to protect their reputation and reduce their exposure by employing the services of due diligence companies tasked with vetting third party intermediaries and identifying easily overlooked government officials embedded in otherwise privately held foreign firms. This strategy is one element of an effective FCPA Compliance Program, as it shows a sincere attempt to avoid business situations where high risk (prior history or proximity to unethical behavior) individuals are concerned.

Regarding payments to foreign officials, the act draws a distinction between bribery and facilitation or "grease payments", which may be permissible under the FCPA, but may still violate local laws. The primary distinction is that grease payments or facilitation payments are made to an official to expedite his performance of the routine duties he is already bound to perform. The exception focuses on the purpose of the payment rather than on its value. Payments to foreign officials may be legal under the FCPA if the payments are permitted under the written laws of the host country. Certain payments or reimbursements relating to product
to make a payment to a foreign official for the purpose of prevail or retain business for or with, or directing business to, any person. Since the 1998 Amendment of FCPA they besides apply to foreign firms and person who take any act in furtherance of such a crooked requital while in the U.S. the meaning of foreign official is broad. For exercise, an owner of a bank who is also the minister of finance would consider as a foreign official according to the U.S. government. Doctors at government - own or managed hospitals are also study to be foreign officials under the FCPA, as is anyone work for a politics - owned or managed institution or enterprise. Employees of international organizations such as the United Nations are besides considered to be foreign officials under the FCPA. A 2014 federal appellate court decision has provide guidance on how the term " foreign official " is defined under FCPA. 

 Because the Act concerns the intent of the bribery rather than the amount, there is no requirement of materiality. offer anything of value as a bribe, whether cash or non - cash items, is prohibited. 

 The FCPA besides command ship's company whose securities are listed in the U.S. to touch its accounting provisions. These accounting provisions engage in tandem with the anti - bribery provisions of the FCPA, and require respective corporations to make and keep record and records that accurately and fairly reflect the transactions of the corporation and to devise and sustain an adequate arrangement of internal accounting controls. An increase number of corporations are taking extra steps to protect their repute and reduce their exposure by employing the services of due application companies tasked with vetting third party intermediaries and identifying well overlooked government officials embedded in differently privately held foreign firms. This scheme is one element of an effective FCPA Compliance Program, as it shows a sincere attempt to avoid business situations where high risk (prior history or proximity to unethical behavior) individuals are refer. 

 Regarding payments to extraneous officials, the act draws a eminence between bribery and facilitation or " grease payments ", which may be permissible under the FCPA, but may still rape local laws. The primary distinction is that grease payments or facilitation payments are make to an official to expedite his operation of the routine duties he is already bound to perform. The exception focuses on the purpose of the payment rather than on its value. payment to foreign officials may be legal under the FCPA if the payments are permit under the write laws of the host country. sealed payments or reimbursements relating to product
 to make a payment to a fortign official for the pucpose or obtainkng or retaining business foc or with, or directing business to, any pvrson. Sinxe tie 1998 Amendment of FCPA thcv alsk appnb to foreign fitms and persmns who take aty aet in furtherance of such a corrupt [ayment wjile in the U.S. the ieanjng of foreign official is broad. Fkr examkle, an owner of a nank who is also the minisher lf finance would clunt as a fireidb official azcording to the U.S. govgrnment. Doctors at government-owndd or managed hispitwns are also conspdered to be npreign officisls under the NCPA, es iw anyone working for e government-owned or managed hnatitution or enteepeise. Gmplofees if knttrnetiknal oggaiizations shch as the Ynited Nations are slfi considered fo be soweign officials under the FCPA. A 2014 federdl zppellate court decisiob has provided guidanfe on how the term "foreign official" is defined under FCPA.

Bacausx ghe Agt cubcfrns the intent of the bribery rather than thq akolnt, there is no rcquirement of matetiwlojy. Offering anithing of balue as a bribe, wjether sash ir non-casr itrms, is prohibited.

The FCPA aoso requires xompanies whose seeurities are lisjed in the U.S. to meet its accuuntjng provisilns. These xccounting provirioks mperate in tandem with the anti-bribxry pxovisionr of the FSPA, and reeuire respective corporahions tm make and keep books and records that acrnrately and fsisly reflect the bransactions of the corporatipn and co devkse and mapntain an adequate srstem of intesjal accountiig controjs. Ab inxreasine number of corlorations are takint additional steps to lrotect their rzkutqtion and reducr tfeiw vxppstse by employhng ghe xervizes of due biuigemce companies tasked witg vetting third pattn intermeeiaries wnd identifyimg easily overlooktd govxrnmenv offiviajs embedded in otherwise privafely held foveign firms. Tris wtrategy is pne element of an effective FCPA Complience Program, as it showw a sincere attempt uo avoid busiiess sytuations where high risk (priir history or prowimity to unethical begavior) indigiduals are concerned.

Regarding payments to foreign officials, the act draww a distinction befweem britexy cnd facylitetmon or "grease paykents", which may be permissible nnder the XC'A, but may still violate locak uaws. The primxry distinction is that frease psyments or facilitation paymentx are made to an officiak to expwdite his pvtfocmance of the routinr dutizs he us alreqdy nound to perfofm. Yhc exceptioj foruszs on the purpose of the payment eather tjan on its value. Payments tl forepgn offycials may be lefal hjder jhe FCPA if thr payments are permitted under the wwitten laws of nhe host counjry. Cetcdin payments or reimburvements relating to product
to make a payment to a foreign the of obtaining retaining business for to, person. Since the Amendment of FCPA also apply to foreign firms and who take any act in furtherance of such a corrupt payment while in U.S. the meaning of foreign official is broad. For example, an owner of bank is the of finance would count as a foreign official according to the U.S. government. Doctors at government-owned managed hospitals are also considered to be foreign under the FCPA, as anyone working for a government-owned managed or enterprise. of organizations as the United are also considered to be foreign officials under the FCPA. A 2014 federal appellate court decision has guidance on term "foreign is under Because the Act intent of the bribery rather than is no requirement of materiality. Offering anything of as a whether cash or non-cash items, is The FCPA also requires companies whose securities are in the U.S. to meet its accounting provisions. These accounting provisions operate in tandem with provisions of the FCPA, require respective corporations make keep and that accurately fairly reflect the transactions of the corporation and to devise and an adequate system of internal accounting controls. An increasing number are additional steps to their reputation and reduce exposure employing the services of companies with intermediaries identifying overlooked government officials embedded otherwise privately held foreign firms. strategy is one element Program, as it shows a sincere attempt to business situations where high risk (prior history proximity to unethical behavior) individuals are concerned. Regarding payments to foreign officials, act draws between bribery and facilitation or "grease payments", which be permissible under the but may still violate local laws. The primary distinction that payments or payments are made an official to his performance of duties he already to focuses on the purpose of the rather on its value. Payments to officials legal under the FCPA if the payments are permitted under the written laws of the Certain payments or reimbursements to
 to make a payment to a foreign oFficial for The puRpoSe oF oBtaiNing Or retaining busINess For or with, or directing buSinesS tO, Any pERsOn. SinCe the 1998 AmENdMENt oF FcPa thEy ALsO applY to Foreign Firms and peRsoNs Who take any acT In FurtherancE of Such a corrupt PayMent whIlE in THe U.S. tHe mEaninG of forEIgn offIcial is brOaD. for exaMPle, an owNER oF a baNk who is also the minIStER of finance woulD count As A FoREIgn OffIcial accorDiNg to tHE U.S. goveRNmENT. docTOrs at governmeNt-owned or maNAgeD hospiTaLs aRE also cOnsidErED to Be foreign ofFiciAls under tHe FCPA, AS is anyoNE workinG for a gOveRnmEnt-oWNeD oR maNaGEd iNStItuTIon Or enterpRiSe. emploYees OF INTernAtiOnal OrganIzations such aS thE UniTEd NAtionS are aLso cOnSiderEd to be ForeiGn Officials under tHe FCpA. A 2014 federaL apPeLlaTe Court DEcisioN haS prOvided gUidance ON hoW tHE TErM "foreign official" is DeFINeD under FCpA.

BecaUSe ThE act conceRnS thE intENT of thE briBErY rather tHan the AMoUnT, there iS nO requiReMenT of MaterIAlitY. OfferIng anythIng of VAlue as a bribe, whETher cash or non-CAsH ITeMS, is pRohIbited.

The FCpA alSO reqUireS CoMpaNIes whOse seCuRItIEs are listed in the U.S. tO mEet its AccouNting provisioNs. These accOUNTing provIsioNS oPErate in tandem wIth thE anti-bribeRY provisiOns of The FCPA, aNd require RESpective CorPorAtiOns TO MaKe and keep bookS ANd reCoRds that AccUrately And FaiRly RefLeCt the tranSactions Of ThE cOrPorAtion ANd to deviSe And MaIntAin an ADequatE systEm of InTeRNal AccountINg CONtroLs. an IncrEasInG numbEr of COrpOrationS are takinG adDItioNaL sTeps to pRotect their rePuTation and rEdUce Their eXPOsure by eMploying the services of duE DiligenCe cOmpanIes tAsked with VetTing thIrd PArty inTermedIarieS aNd iDENtifyING eAsiLy Overlooked GOVerNment OfFiciAls embeDded in otherwise priVAteLy held foreign FirMs. ThIS StRatEGy IS onE eLEmeNT Of an effective FCpA ComplianCe pRoGram, as it shOWs a SiNcere atTempt to Avoid BUsiness SituationS where higH rIsk (pRIOr hIstory or prOximity tO unethicaL BehavIOr) IndivIduAls are CoNceRned.

REgardiNG paYmentS to forEiGn offiCials, ThE act drawS a distinction between briBery anD faciLitAtion or "grEasE PayMents", whicH may Be permissiBle UndEr the fCPa, But maY stiLL vIolATe locAl laWS. The primaRY dIstINCtIon is that grEASE paYmentS or FAcilitAtioN payments are made tO An official to exPediTE His PerFOrmaNcE of the routine dUtiEs HE Is alreadY bOund to perfoRm. The excEpTIon foCuses oN the puRpose of THE pAYment rAtheR thAn on its vaLue. paYMents to FoReIGn offiCialS mAy be leGal undER the fcpA if the payments aRe perMITted uNDer The wrItTen laws OF the Host countrY. Certain payMents oR reiMbursEments rElAting tO prOdUct
 to make a payment to a fo reign offi cialfor  th epurp oseof obtaining o r  ret aining business for or  with ,o r di r ec tingbusines s  t o ,  an ype rso n. Si nce t he1998 Am endment of  FC PA  they also a p pl y to forei gnfirms and pe rso ns who  t ake any a ctin fu rthera n ce ofsuch a co rr u pt pay m ent whi l e  i n th e U.S. the meanin g  o f  foreign offic ial is  b r oa d .  Fo r e xample, an  o wnero f a ban k  w h o isa lso the minis ter of fina n cewouldco unt as a f oreig no ffi cial accord ingto the U. S. gov e rnment. Doctors  at go ver nme nt-o w ne dorma n age d  h osp i tal s are al so  c onsid ered t o be f ore ignoffic ials under th e F CPA, asis an yonework in g for  a gov ernme nt -owned or manag ed i nstitutio n o rent er prise .  Emplo yee s o f inter nationa l  or ga n i z at ions such as the U ni t e dNationsare al s oco n sideredto  be  for e i gn of fici a ls  under t he FCP A .A2014 fe de ral ap pe lla tecourt deci sion h as provi ded g u idance on howt he term "fore i gn o ff i cial " i s defined u nder FCPA .

B e ca use the A ct co nc e rn s  the intent of thebr iberyrathe r than the am ount, ther e i s no req uire m en t  of materialit y. Of fering any t hing ofvalue  as a br ibe, whet h e r cash o r n on- cas h i t e ms , is prohibit e d .

T he  FCPA a lso  requir escom pan ies  w hose secu rities a re  l is te d i n the U.S. tome etit s a ccoun t ing pr ovisi ons.  T he s e a ccounti n gp r ovis io ns  ope rat ein ta ndem wit h the a nti-bribe ryp rovi si on s of th e FCPA, and r eq uire respe ct ive  corpo r a tions to  make and keep books an d  record s t hat a ccur ately and  fa irly r efl e ct the  trans actio ns  of t he co r p or ati on  and to de v i seand m ai ntai n an ad equate system of i n ter nal accountin g c ontr o l s.  An in c rea si n g n u m ber of corporat ions are t ak i ng  additiona l  st ep s to pr otect t heirr eputati on and re duce thei rexpo s u reby employi ng the s ervices o f  dued il igenc e c ompani es  ta skedwith v e tti ng th ird pa rt y inte rmedi ar ies andidentifying easily over looked  gove rnm ent offic ial s  em bedded in  oth erwise pri vat ely  held  fo r eignfirm s .Thi s  stra tegy is one el e me nto f  a n effective F C PACompl ian c e Prog ram,  as it shows a si n cere attempt t o av o i d b usi n esssi tuations where  hi gh r isk (pri or  history or  proximi ty to un ethica l beha vior) i n d iv i dualsarecon cerned.
Reg ar d ing pay me nt s  to fo reig noffici als, t h e ac t draws a distinct ion b e t weenb rib ery a nd  facili t atio n or "grea se payments ", whi ch m ay be  permis si ble un der  t he FCPA, b u t may sti ll vi olate l oc al l aws . Theprim a r y dis tinc ti onis that g r e as e  p ay m ent s or  faci li tati on paymen t s are ma det o an of fi cia l to exp e di t e  his perfo rma nce o f the routin e  dut i es he is  alrea dy bou nd to p e rfo rm . The e xce p t ion focus es on the pur po se o f the pa ym entra the rthan on its val ue. Paym ents tof o reignoff i cial s  may b elegal underthe F CP A  if the p aym ents ar e  pe rmi tte d un der  the written laws of the host  cou ntry. Cer tainpayme nt s or rei m burs ements r e lating to pro duct
 to_make a_payment to a foreign_official for_the_purpose of_obtaining_or retaining business_for or with,_or directing business to,_any person. Since_the_1998 Amendment of FCPA they also apply to foreign firms and persons who take_any_act in_furtherance_of_such a corrupt payment while_in the U.S. the meaning_of foreign_official is broad. For example, an owner of_a_bank who is_also the minister of finance would count as a_foreign official according to the U.S._government. Doctors at_government-owned_or_managed hospitals are also_considered to be foreign officials under_the FCPA, as is anyone working_for a government-owned or managed institution or_enterprise. Employees of international organizations such_as the United Nations are_also considered_to be foreign officials under_the FCPA. A_2014 federal_appellate court decision_has provided guidance on how the_term "foreign official"_is defined under FCPA.

Because the Act_concerns_the intent of_the_bribery_rather than_the amount, there_is_no requirement_of_materiality. Offering anything of value as_a_bribe, whether cash or non-cash items, is_prohibited.

The FCPA also requires_companies_whose securities are listed_in the U.S. to meet_its accounting provisions. These accounting provisions_operate in_tandem with_the anti-bribery provisions of the FCPA, and require respective corporations to_make and keep books and records_that accurately and fairly_reflect the_transactions_of the corporation_and_to devise_and maintain an adequate system of internal_accounting controls._An increasing number of corporations are_taking additional steps to_protect_their reputation and reduce their exposure_by employing the services of due_diligence companies tasked with vetting_third_party_intermediaries and identifying easily overlooked_government officials embedded in otherwise privately_held foreign firms._This strategy is one element of an_effective_FCPA Compliance Program, as it shows_a_sincere attempt to avoid business situations_where_high_risk (prior history or proximity_to unethical behavior) individuals are concerned.

Regarding_payments to foreign officials, the act draws a distinction_between bribery and_facilitation or "grease payments", which_may_be_permissible under the FCPA, but may still violate local laws._The primary_distinction is that_grease payments or facilitation payments are made to an official_to expedite his performance of the routine_duties he is already bound to perform. The exception focuses on_the purpose of the payment rather than on_its value. Payments to foreign officials may_be legal under the_FCPA_if the payments are permitted under the_written_laws_of_the host country._Certain payments or_reimbursements relating to_product