FCPA Gifts, Entertainment and Hospitality: Surviving DOJ and SEC Enforcement

Understanding the Risks, Avoiding Common Pitfalls, and Strengthening Compliance Programs to Meet FCPA Requirements

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Wednesday, May 17, 2017

Recorded event now available

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Course Materials

This CLE course will provide guidance for counsel to companies doing business internationally on how the DOJ and SEC currently view gifts, entertainment and hospitality under the Foreign Corrupt Practices Act (FCPA). The panel will review recent FCPA enforcement trends in this arena and offer best practices for strengthening compliance programs to avoid such violations and sanctions.


The DOJ and SEC’s intense scrutiny on FCPA enforcement continues unabated. U.S. companies doing business internationally must be particularly careful to avoid running afoul of FCPA requirements pertaining to gifts, entertainment and hospitality in the course of conducting business.

Recent investigations and subsequent DOJ and SEC enforcement actions related to gifts, travel, and excessive entertainment against Olympus, which resulted in over $22 million settlement, and against PTC, which was settled for $28 million, demonstrate the need for counsel to guide clients in developing, implementing and monitoring solid gift-related FCPA compliance policies and training.

The FCPA Resource Guide does include SEC/DOJ positions on gifts and hospitality with foreign officials. However, the history and recent enforcement indicate that gift practices are rife with grey areas as businesses navigate a tricky balance between obeying the law and respecting local customs.

Listen as our authoritative panel of practitioners experienced with FCPA challenges examines the provisions of the law that address gifts and hospitality, discusses DOJ advisory opinions and recent cases, and offers best practices for compliance.



  1. Provisions of the FCPA addressing gifts and hospitality
  2. Advisory opinions and recent cases
    1. Qualcomm
    2. PTC Inc.
    3. Olympus
    4. SciClone
    5. Others
  3. Best practices for compliance


The panel will review these and other key issues:

  • Does the FCPA allow any leeway for companies regarding hospitality—and when is it permissible under the law?
  • When do gifts to foreign officials cross the line from respecting local customs and culture to being viewed as bribery?
  • What strategies can counsel offer companies to ensure their staffs are fully compliant with the FCPA with regard to gift giving, travel, entertainment and hospitality?
  • What guidance is offered in the FCPA Resource Guide as well as recent enforcement actions, advisory opinions, and settlements for gift and hospitality conduct?


Cassidy, Margaret
Margaret M. Cassidy

Cassidy Law

Ms. Cassidy's practice focuses on corporate compliance, internal investigations and white collar criminal defense....  |  Read More

Davis, John
John E. Davis

Member and FCPA/International Anti-Corruption Practice Lead
Miller & Chevalier

Mr. Davis focuses his practice on international regulatory compliance and enforcement issues. He advises on corruption...  |  Read More

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