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Even though FCPA only forbids bribes to government offi cials and allows for modest facilitation payments-payments to accelerate the pace of a normal business transaction, and yes, they are as legally vague as that sounds-some companies aren't taking any chances. "We previously had strongly discouraged facilitating payments," says Dan Dorsky, senior FCPA compliance counsel at Tyco International.
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"Bribery Act Setting a New Standard for Compliance"Please download to view full document