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Gifts, Entertainment & Hospitality in High Risk Markets - A Practical Guide on What You Can, and Can't Do

November 15, 2010
Washington, DC

24th Global Conference on Foreign Corrupt Practices Act

This interactive and practical working session will go beyond high-level understanding of the FCPA to identify concrete tools and tactics for avoiding the loopholes presented by the cultural expectations of gift giving, entertainment and hospitality in high risk markets.

The workshop will include an interactive session on how to decide, document, and review decisions relating to gifts, travel and entertainment, including:

  • Hospitality: managing the "reasonable and customary" standard across multiple jurisdictions
  • Gifts: when gifts, benefits or sweetheart deals masquerade as "cultural sensitivity"
  • Travel: managing the expectations of local government officials
  • Cash: weddings, funerals and little red envelopes
  • Involuntary payments: when intentions are good, but controls are weak
  • Business travel 101: first class travel, corporate jets, spouses, family members and boondoggle

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