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FCPA Blog Daily News

Entries in Per Diem (4)

Wednesday
Aug242016

Bill Steinman: Getting comfortable with per diems by mitigating the risk

Per diems abound. Since my first post in this series six months ago, I’ve been asked to help our clients with at least fifteen foreign government tenders or contracts that require the payment of per diems during testing or training visits. While not a scientific survey, it underscores what I believe to be a growing demand by foreign governments for per diems. 

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Tuesday
Jul192016

Bill Steinman on per diems: What not to do

Let’s recap. In my first post, I examined a limited set of circumstances where I believe it is reasonable under the FCPA to pay per diems to foreign officials.

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Tuesday
Apr122016

Bill Steinman: Let's talk about per diems, without the shouting

Per diems. We in the FCPA bar love to hate them, and with good reason. Who likes the idea of giving cash to foreign officials? If there’s anything that should rankle the anti-corruption specialist, this is it. 

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Wednesday
Mar022016

Bill Steinman: How to handle mandated per diems with foreign government customers

Most FCPA Blog readers know that the FCPA contains an affirmative defense under which companies may incur expenses, such as meals or travel costs, on behalf of foreign government officials, so long as those expenses are reasonable and bona fide, and directly related to either showing off the company’s wares or executing or performing under a foreign government contract. 

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