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.
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."
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?
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.