Page 170 - CFF
P. 170
FCPA investigations (continued)
FCPA requirements (continued)
• No material threshold
– Expenditures deserving special consideration
– Travel and entertainment expenses
– Gifts and donations
– Donations
– Exempted payments
– Promotional expenditures
– Must be bona fide and reasonable
– Must relate to promotion, demonstration, or explanation of products or performance of a
contract with foreign government
21
21 © 2019 Association of International Certified Professional Accountants. All rights reserved.