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.