By Adam Turteltaub
Recently the FCPA blog ran an article asking whether small bribes – they characterized them as less than $1 million – ever led to prosecutions. The answer, they explained, is yes and included in their blog post is a large number of cases and the amount of the bribes involved. The smallest bribe was “just” $22,000.
There may be smaller, but what’s notable is that it belies the argument that the FCPA is too vague and business doesn’t know if a cup of coffee would be considered a bribe. A cup of Starbucks is expensive, but it’s nowhere near $22,000.
There are those who like to use scare tactics when it comes to compliance. They argue that business doesn’t know what may be considered a bribe. Some say that the new Administration in Washington will get rid of so many regulations and cut off enforcement, obviating the need for compliance.
All this fear mongering is just an unnecessary distraction from the need for the compliance community to stay focused and to remind the businesses that they serve, that, no matter what the fear mongers may see, the public, press and government have no appetite for wrongdoing and expect reasonable, lawful, ethical conduct by business.
So let’s buy ourselves a cup of coffee, get to work, and leave the fear mongers to scare each other.
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