Paying the additional charge is considered a grease payment and is permitted under the law.
For example, employees responsible for making legal grease payments should get extra training in this specific part of the FCPA.
Keeping business above board
Payments that are permissible under the FCPA, however, are called facilitating or
grease payments. This exemption allows for payments to be made to a foreign official, political party or party official for the sole purpose of carrying out and ensuring "routine governmental actions."
How company size influences FCPA enforcement
In 2009, the The Organisation for Economic Co-operation and Development did a U-turn and called for the end of facilitating payments, also known as "
grease payments," tolerated by several governments.
More Than A Few Rotten Apples: Why We Can't Trust Bankers Any More
An exception to the FCPA's antibribery prohibition exists for "
grease payments," or payments to facilitate or expedite performance of a "routine governmental action." Which of the following is NOT considered a "routine governmental action," as defined by the FCPA?
What's your fraud IQ?
The actions ranged from bribery of foreign officials to facilitating payments (or "
grease payments") to ensure certain ministerial or clerical duties got done on time.
The next great fed crackdown: the foreign corrupt practices act is experiencing a resurgence