John Davis's Presentation on Anti-Corruption Compliance Summarized in The FCPA Report

"Gifts, Travel, Entertainment and Anti-Corruption Compliance: Sources of Authority, Best Practices and Benchmarking"
The FCPA Report
11.06.13This article summarizes key takeaways from John Davis's recent presentation on "FCPA Gifts, Entertainment and Hospitality: Surviving Heightened Enforcement." Davis addressed a variety of issues related to gifts, travel and entertainment of foreign officials, including a discussion of the statute's language, the Department of Justice(DOJ)/SEC Guide and DOJ opinions examining factors that the government may consider in determining appropriate and inappropriate expenditures, and summaries of recent settled enforcement actions. Davis noted the importance of considering the reasonableness, transparency, and local law treatment of gifts within particular circumstances, and cautioned that different contexts can yield varying consequences, for example related to the upcoming World Cup in Brazil. Davis also discussed the challenges of third parties used in the travel and entertainment context, as well as the need for benchmarking best practices to manage corruption risks.
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