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.