This sample provision illustrates how to incorporate a necessary element of a comprehensive FCPA program into your company’s compliance library and is designed to help compliance professionals ensure they have considered all of the issues. Certification language for a policy provision covering facilitating payments must clearly state employees’ responsibilities in dealing with so-called grease payments.
A detailed due diligence checklist form licensed from the American Health Lawyers Association, adapted, revised and fully annotated by Ropes & Gray, LLC with assistance from Bloomberg Law editorial staff. The checklist included is a sample for a simple, small-dollar transaction in the United States involving a general healthcare provider or supplier.