The Disappearing Exception for Facilitating Payments

Agencies take narrow view of this FCPA defense.

, New York Law Journal


Kevin J. Harnisch, Steven M. Witzel and Joshua D. Roth of Fried, Frank, Harris, Shriver & Jacobson examine the evolution of the "facilitating payments" exception to the Foreign Corrupt Practices Act, the new DOJ/SEC Guide's treatment of that exception, and the extent to which such payments remain permissible.

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