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

Conducted on Wednesday, May 17, 2017
Recorded event now available

This CLE webinar 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?


Margaret M. Cassidy, Principal
Cassidy Law, Washington, D.C.

Ms. Cassidy's practice focuses on corporate compliance, internal investigations and white collar criminal defense. She has provided expertise on matters related to anti-corruption, the Foreign Corrupt Practices Act, ethics laws, the False Claims Act, political activity, government procurement, and conflicts of interest. As a seasoned criminal litigator, Ms. Cassidy has also tried over 100 jury and non-jury criminal cases to verdict.

John E. Davis, Member
Miller & Chevalier, Washington, D.C.

Mr. Davis focuses his practice on international regulatory compliance and enforcement issues. He advises on corruption issues around the world, including compliance with the FCPA and related laws and international treaties, and FCPA-related internal investigations and disclosures to the SEC and DOJ. Mr. Davis works with clients to develop and implement compliance programs, conduct due diligence and audit compliance processes.


CLE On-Demand - Streaming Video

Includes recorded streaming video of full program plus PDF handouts.

On-demand is the only recorded format recognized for CLE credits in DE, IN, KS, LA, MS, NC, OH, OK, SC, TN, VA, WI.

AK, AZ, CA, CO, CT, DE, FL, GA, HI, IA, ID, IL, IN*, KS, KY, LA, ME, MN, MO, MT, NC, ND, NH**, NJ, NM, NV, NY, OH*, OK, OR, PA, SC, TN, TX, UT, VA, VT, WA, WI, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)

*Only available for attorneys admitted for more than two years. For OH CLE credits, only programs recorded within the current calendar year are eligible - contact the CLE department for verification.

**NH attendees must self-determine if a program is eligible for credit and self-report their attendance.

CLE On-Demand Video $297.00

How does this work?

Recorded Event

Includes full event recording plus handouts.

Strafford is an approved provider and self-study CLE credit is available in most states.

AK, AZ, CA, CO, CT, FL, GA, HI, IA, ID, IL, KY, ME, MN, MO, MT, ND, NJ, NM, NY, OR, PA, TN, TX, UT, VT, WA, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)

Strafford will process CLE credit for one person on each recording.

Additional copies of a recording can be purchased at a discount. Please call Strafford Customer Service toll-free at 1-800-926-7926 ext 10 or email customerservice@straffordpub.com to place your order.

Recorded Webinar Download $297.00

How does this work?

Recorded Audio Download (MP3) $297.00

How does this work?


Strafford webinars offer several options for participation: online viewing of speaker-controlled PowerPoint presentations with audio via computer speakers or via phone; or audio only via telephone (download speaker handouts prior to the program).  Please note that our webinars do not feature videos of the presenters.

Program Materials

Requires Adobe Reader 8 or later. Download Acrobat FREE.

Program Materials

Requires Adobe Reader 8 or later. Download Acrobat FREE.

or call 1-800-926-7926

CLE Credits

Many states grant CLE credits for on-demand streaming audio programs and recorded events. Our programs are pre-approved in many states. Refer to our state CLE map for state-specific information.

or call 1-800-926-7926

Customer Reviews

I appreciated that I got exactly what I expected from Strafford’s webinar and I thought the presentation was fantastic. I would love to see more webinars like this.

Brian Cromer

Sempra LNG

There was a lot of information available on the slides, so it was easy to take notes and have a thorough take-away resource.

Harriet Bildsten

St. Jude Medical

I appreciated the personal-level insights of the speakers.

Kendall Carter

King & Spalding

All of the speakers were very informative, and being able to ask questions was very helpful.

Larry V. Smith

Jackson Walker

The seminar was well presented and the topic was tied very well to real life examples.

Anne Turner

Phelps Dunbar

or call 1-800-926-7926

International Law Advisory Board

Edward J. Fishman



Judith A. Lee


Gibson Dunn & Crutcher

Greta Lichtenbaum


O’Melveny & Myers

Kimberly A. Parker



Kyle A. Wombolt


Herbert Smith

or call 1-800-926-7926

Our Guarantee

Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.