Lost in Translation: The Language of Bribery

Corporate Governance Advisor
In this article, James Tillen and Sonia Delman discuss the language of bribery. Bribes can hide behind terms ranging from innuendo to elaborate code words. A matter of local dialect or custom, these words can mislead those outside the transaction. The FCPA prohibits companies and individuals subject to its jurisdiction from making corrupt payments to non-U.S. officials. To help their employees recognize and prevent improper payments to officials, companies must create effective compliance policies and training programs. Such programs need to be tailor-made to the environment in which they will be applied. They should use the language, the dialects, the customs, and the cultural norms of the countries where the company operates.
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