Travel and Entertainment (T&E) audits may uncover erroneous spend, but sometimes the money spent on the "receiver" may not be monitored for excessiveness. And, when that "excessiveness" appears to be in the form of a bribe, you or your company may be heavily fined.
The FCPA does not allow any form of cash, gifts, vacations, meals and entertainment to foreign government officials that may be viewed as a bribe to receive business. A foreign official, per the definition, includes a very wide scope. According to William Bosch and Jonathan Drimmer, contributors to Hotel News Now, the FCPA is the Justice Department’s second highest law enforcement priority after terrorism. Currently, there are about 100 companies subject to open FCPA investigations and many more against individuals. They cite numerous companies that have already been fined millions of dollars in their article -à http://www.hotelnewsnow.com/Articles.aspx?ArticleId=1338&print=true
Should you review your T&E policies? Maybe review the controls you have in place so that you're not fined? Please feel free to reach out to me.
Debi Scholar, CMM, CMP, CTE, CTT
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