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…