A Bribe By Any Other Name

With fines and penalties for violations of anticorruption laws skyrocketing, multinational companies are pouring more resources into anticorruption compliance. In doing so, they should pay particular attention to the language of bribery, explain James Tillen and Sonia Delman. For multinational companies employing a mix of expatriate and local workers in numerous countries, the morass of bribery slang and custom may spell legal trouble. The U.S. Foreign Corrupt Practices Act (FCPA), the recently passed U.K. Bribery Bill and several other laws prohibit making corrupt payments to public officials worldwide. When an expatriate manager does not recognize that a subordinate is seeking reimbursement for a bribe disguised by a code word or when auditors miss a suspect transaction concealed behind a local idiom, the employees themselves and the company as a whole are at serious risk of running afoul of anti-bribery laws.
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