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#反腐败

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Jun 29Wed
  1. SAP Concur Blog

    Proactively Mitigating FCPA Risk in a Global Business Landscape

    A SAP Concur blog post states that the Foreign Corrupt Practices Act (FCPA) anti-bribery provisions prohibit giving anything of value to a foreign official to obtain or retain business, and enforcement actions often involve leisure activities such as travel, meals, gifts and entertainment. It says the definition of government official extends to employees of government departments or agencies, state-owned enterprises, healthcare providers and even third-party consultants helping plan hospitality events. It outlines five compliance steps: understanding your business network, implementing controls, maintaining clear records, building a comprehensive audit process and educating on clear polici…

  2. SAP Concur Blog

    FCPA Enforcement Continues to Focus on Corporate Hospitality

    A SAP Concur blog post notes that U.S. Foreign Corrupt Practices Act (FCPA) enforcement actions continue to focus on corporate hospitality spending. Recent cases involved gift cards, spa services, sightseeing tours, shopping excursions, national park excursions and sporting-event tickets. The FCPA treats employees of state-owned or state-controlled companies and foreign health care providers as 'foreign officials,' so providing things of value to them can trigger risk. The post advises companies to track hospitality expenditures and set oversight criteria, and cites government-commended remedial measures such as compliance oversight across a broad category of business expenditures and pre-a…

  3. SAP Concur Blog

    FCPA Risks: How Travel and Expense Play a Critical Role in Mitigation

    SAP Concur published an article analyzing an FCPA enforcement action announced by the DOJ and SEC in August 2020. Two employees of a health and personal care products company operating in China received approximately $775,000 in reimbursements over fewer than six months through fake meal and gift invoices to fund a bribery scheme. The company agreed to pay $123 million. The article also covers the DOJ's revised Evaluation of Corporate Compliance Programs (ECCP), emphasizing that compliance personnel need sufficient data access for timely and effective monitoring.

  4. SAP Concur Blog

    New FCPA Enforcement Actions: Are You Mitigating This Risk?

    SAP Concur published an article analyzing two recent FCPA enforcement actions by the U.S. Department of Justice (DOJ). Both cases were resolved through 'declinations with disgorgement,' with companies paying approximately $11.2 million and $4 million respectively. The DOJ stated that lenient treatment was based on timely voluntary self-disclosure and full cooperation. The article also outlines the FCPA Pilot Program framework for voluntary self-disclosure and full cooperation, and recommends companies manage risk through T&E tool configuration, data visibility, and compliance reporting.